A years-old relic of the Trump-Ukraine scandal—a dossier that was aggressively promoted by Rudy Giuliani—is coming back to haunt him, just as federal law enforcement has ramped up its investigation into the former New York City mayor.
The dossier, a collection of documents centered with wild corruption accusations against Joe Biden, Marie Yovanovitch, and other officials, was widely and almost instantly dismissed as irrelevant ramblings, conspiracy theories, and political smears when it emerged in 2019. But Giuliani pushed it anyway to the highest echelons of the Trump White House and to Secretary of State Mike Pompeo.
Now, his efforts have been scrutinized by federal investigators, according to two people familiar with the matter. In a probe that began during former President Donald Trump’s time in power, the feds have been investigating whether some of Giuliani’s activities during the Trump-Ukraine saga amounted to unregistered and illegal lobbying on behalf of foreign figures.
Giuliani's legal team did not respond to requests for comment on this story. A spokesperson for the U.S. Attorney’s Office in the Southern District of New York declined to comment. But Giuliani’s pushing of the dossier is one of a number of activities under investigation by federal law enforcement. Another, The Daily Beast has learned, is his attempts to introduce a conspiracy-peddling Ukrainian prosecutor general to then-Attorney General William Barr.
Last month, federal agents executed search warrants on Giuliani’s apartment and office, seeking access to his mobile devices and communications between the prominent Trump adviser and lawyer and roughly a dozen people, including Ukrainian former prosecutors who had served as sources for Giuliani’s various corruption allegations against the Biden family.
The document reportedly prompted intrigue followed by disappointment when the State Department turned it over to House impeachment investigators. Rep. Jamie Raskin (D-MD) described the dossier to The New York Times as “a series of hallucinatory propagandist suggestions.”
In late 2019 during the Trump-Ukraine scandal, The New Yorker, which obtained a copy of the dossier, described one of its allegations as a byzantine conspiracy theory in which the U.S.-backed creation of NABU— Ukraine’s anti-corruption prosecutors—in 2014 was somehow a scheme concocted by Ambassador Yovanovitch and Deputy Assistant Secretary of State George Kent to prevent Ukraine from investigating the Bidens. In another allegation described by the magazine, the dossier casts right wing boogeyman and liberal philanthropist George Soros as the orchestrator of Yovanovitch’s appointment as U.S. ambassador in Kyiv.
Rather than a single, coherent narrative, the dossier is reportedly a collection of various memos, public information and articles, and notes from Giuliani’s interviews with Ukrainian prosecutors like Viktor Shokin and Yuriy Lutsenko and filled with wild and unsubstantiated allegations against Yovanovitch, Joe Biden, and his son Hunter. Giuliani described the dossier to CNN more as an “outline” that he “routed” to the State Department. “They told me they were going to investigate it,” he told the cable news outlet in late 2019.
Multiple former senior Trump administration and White House officials who had seen the dossier at the time privately describe the Giuliani-compiled research as a waste of time. They viewed it as a nuisance, a feckless attempt to bring down the Bidens. What these ex-officials did not predict was that it could one day be used in a federal investigation against Giuliani himself.
According to one former Trump White House official, those in the White House who examined the pages and interview notes in 2019 almost across-the-board dubbed the research “amateurish” and unhelpful, with Trump officials discussing amongst themselves how they believed it was unlikely that anyone, foreign or American, would agree to pay Giuliani to produce this—if only because of the utterly shoddy nature of the work.
Giuliani told the Times that the memos of his interviews were put together by a “professional investigator who works for my company” and that he passed them along to Secretary of State Pompeo in March of 2019—a month before Yovanovitch was removed as ambassador—in the hopes that Pompeo would forward the material along to the FBI and “it won’t look like I’m pushing the FBI to do it.”
Under the Foreign Agents Registration Act, anyone seeking to politically influence the American public or government must register with the Justice Department. Giuliani has repeatedly denied that he has engaged in lobbying activity and says that all of his work on Ukraine was carried out on behalf of his client, President Trump.
Federal investigators have also been looking into Giuliani’s relationship to Lutsenko, a former Ukrainian prosecutor general who helped feed Giuliani’s Biden conspiracy theories, and to what extent Giuliani participated in Lutsenko’s quest to secure a meeting with then-Attorney General Barr, two sources familiar with the situation told The Daily Beast.
Before he linked up with Giuliani, Lutsenko had tried to set up his own direct channel to senior Justice Department officials. In September 2018, he hired Bud Cummins, a lobbyist and former U.S. Attorney for the Eastern District of Arkansas, through unnamed intermediaries in an attempt to push his Biden corruption theories to “high-level” Justice Department officials, Cummins told ABC News.
And in testimony before the House impeachment panel, Yovanovitch said that Lutsenko had repeatedly tried to get the U.S. embassy in Kyiv to "set up meetings with the Attorney General, with the Director of the FBI" but that he had refused to follow normal procedures and share his allegations with FBI legal attachés in the embassy.
Lutsenko told The New Yorker that he’d approached Giuliani because he thought the president’s attorney could secure a meeting with then-new attorney general to discuss an effort to recover millions of dollars looted from the country during its former pro-Russian government.
According to Lutsenko, Giuliaini agreed to help. Giuliani claimed that he chose not to personally lobby Barr for the meeting, adding—in a moment of apparent self-awareness—that, “I don’t know what crime they would have made out of that.”
But the meeting never happened. And Lutsenko claimed in an interview with Ukrainskaya Pravda that when he followed up with unnamed advisers to Giuliani about why a meeting with Barr had not materialized, they told him that “the meeting was impossible until I hired a company to lobby for the meeting, because, they say, this is the law in the United States.”