The Lobbying Battle Before the War: Russian and Ukrainian Influence in the U.S.

Introduction

For Ukraine, relations with the U.S. are more important now than they have ever been. As of this writing, Ukraine has been at war with an invading Russian army for more than five months. The consequences of Putin’s decision to invade Russia’s sovereign neighbor and attempt to depose its democratically elected government have been devastating. Thousands of Ukrainian soldiers have been killed and thousands of Ukrainian civilians have been murdered in seemingly indiscriminate Russian attacks that U.S. President Joe Biden has described as “war crimes.”¹

Russia, too, has brought devastation upon itself with its military invasion. Tens of thousands of Russian soldiers have been killed or injured fighting in Ukraine² while the Russian economy has been decimated by crippling sanctions and other actions by the U.S. and many other nations.³

The February 24 invasion has had grave implications globally, but the roots of the conflict date back to the fall of the Soviet Union. As Anatol Levien, my colleague at the Quincy Institute, has explained.⁴ U.S. involvement in tensions between Russia and Ukraine can be traced back to the fall of the Soviet Union when ties with Ukraine, most notably military ties, began to steadily increase. Between 2014 and 2021, for example, the U.S. provided $2.7 billion dollars worth of military assistance to Ukraine and trained more than 10,000 Ukrainian soldiers, according to a Stimson Center analysis.⁵

While Ukraine was bracing for the possibility of a Russian invasion, it was simultaneously fighting an economically critical battle over the Nord Stream 2 pipeline, which runs through the Baltic Sea. The pipeline would have allowed Russia to export natural gas directly to Germany and the rest of Europe, jeopardizing the billions of dollars Ukraine currently earns from transiting Russian gas to Europe.⁶

Russia’s February 24, 2022 military invasion of Ukraine was the death knell for Nord Stream 2. German Chancellor Olaf Sholz announced that Germany would not allow the pipeline to become operational, saying that “the situation has fundamentally changed.” The U.S. quickly followed up by sanctioning Nord Stream 2 AG, the company behind the pipeline.⁷

While these might seem like disparate economic and military issues going through typical political dynamics in the U.S. foreign policy process, they are all underpinned by extensive lobbying by both sides. Each of these issues has been the object of considerable lobbying, public relations, and related attempts at influence by Ukraine’s foreign agents in the U.S., referred to here as the pro-Ukraine lobby, and agents representing Russian interests in the U.S., referred to here as the pro-Russia lobby.⁸

Since Russia’s invasion, the pro-Ukraine lobby has won nearly every concession they sought from Congress and the executive branch. Aided by an American public that is overwhelmingly supportive of Ukraine in its time of need and facing little opposition—nearly all lobbying and public relations firms quickly severed ties with their Russian clients following the invasion and U.S. sanctions⁹—the pro-Ukraine lobby scored a major victory when the Biden administration levied U.S. sanctions on the Nord Stream 2 pipeline, something the pro-Ukraine lobby had been pursuing for years. With this victory, and Biden’s ban on oil and gas imports from Russia, in hand, the pro-Ukraine lobby went from focusing on “energy security to security,” as one lobbyist described the pro-Ukraine lobby’s new focus on obtaining U.S. military support for Ukraine’s war with Russia.¹⁰ This advocacy push, aided immensely by the vigorous efforts of President Volodmyr Zelensky, found phenomenal success as the U.S. Congress and Biden approved tens of billions of dollars in military aid to Ukraine.¹¹

Prior to the February 24 invasion, the pro-Ukraine lobby had, for years, been battling an extremely well-financed collection of lobbying, public relations, and other firms working for Russian interests. Despite the extraordinary efforts of the pro-Ukraine lobby, in 2021 the Biden administration lifted sanctions on the Nord Stream 2 pipeline; in January, the Senate voted not to re-implement them.¹² After the February invasion, however, earlier lobbying efforts proved critical in facilitating the decisive shift in U.S. decision making to favor Ukraine.

This report aims to provide an analysis of the lobbying battle between Russian and Ukrainian interests prior to Russia’s February 24 invasion of Ukraine. In 2021, U.S. foreign policy decisions regarding Russia and Ukraine were still very much in doubt. In just one year Ukrainian interests were represented by 11 firms in the U.S.; those firms reported contacting policymakers, media, think tanks, and others an astounding 13,541 on behalf of their Ukrainian clients and received more than $2 million from their Ukrainian clients for this work.¹³ Russian interests, by contrast, were represented by 13 different firms which received just over $42 million in 2021. Though, it should be noted that an overwhelming portion of this—more than $38 million—came from Russian state media, which the Department of Justice forced to register as a foreign agent in 2017.¹⁴

My colleagues at the Quincy Institute and I analyzed every Foreign Agents Registration Act (FARA) document filed by organizations registered to work on behalf of Ukrainian and Russian clients in 2021.¹⁵ From these documents, we recorded every single “political activity” done for those clients, “informational materials” distributed on behalf of these clients, and funds these organizations reported receiving from their Ukrainian and Russian clients.¹⁶ We also analyzed all Lobbying Disclosure Act (LDA) filings made by firms working on behalf of Russian interests. We then analyzed all of this in an attempt to follow the money, connect the dots, and provide the public with a better understanding of the legal channels Ukrainian and Russian interests have used to influence U.S. foreign policy.¹⁷

By the numbers: Russian and Ukrainian influence

This section provides an overview of the U.S. lobbying, public relations, and other firms working for Ukrainian and Russian interests in 2021, including the money they received and the activities conducted on behalf of their foreign clients. 

The Pro-Russia lobby by the numbers

The unprecedented activity of the pro-Ukraine lobby, as discussed below, stands in stark contrast to the pro-Russia lobby, which reported just 21 political activities in 2021. This remarkable discrepancy stands in spite of Russian interests outspending Ukrainian interests by more than two-to-one, excluding the more than $38 million spent on Russia state media in the U.S. While much of this spending went toward Russian state media operations at RT and Sputnik, which do not report engaging in political activities aside from distributing their media content, many firms in the pro-Russia lobby were traditional lobbying and public relations firms that simply did not report any political activities. In fact, just one firm, Mercury Public Affairs, which represented En+ Group, the Russian energy and metals firm linked to oligarch and Putin ally Oleg Deripaska, reported any political activities.

There are a variety of plausible explanations for this lack of reported political activity, not the least of which is that some of the firms receiving money from Russian interests just didn’t do any work for them, as Matthew Jay Lauer and Sidley Austin LLP (representing TENEX) explained in their FARA filings.¹⁸ Another reason for the discrepancy in reported political activities is that, unlike Ukrainian interests, some firms representing Russian interests registered under the LDA. There is an exemption to FARA registration for firms that are registered under the LDA, though FARA regulations make clear that this exemption is not available when a foreign government directs or directly benefits from the lobbying activities.¹⁹ Firms often prefer to register under the LDA because its reporting requirements are much less stringent than those specified by FARA—i.e., it does not require registrants to report individual political activities, as FARA does. Specifically, firms representing Nord Stream 2, the firm behind the highly contested natural gas pipeline from Russia to Germany, registered under the LDA rather than FARA.

There is ample reason to question whether this was appropriate. First, the FARA statute provides an exemption from registration to firms registered under the LDA and engaging, “only in private and nonpolitical activities in furtherance of the bona fide trade or commerce of such foreign principal.”²⁰ However, given the extraordinary politicization of Nord Stream 2, which for years has been the subject of congressional and executive branch actions, it would seem challenging to lobby for Nord Stream 2 and not engage in political activities.

Second, FARA regulations state that registering under the LDA in lieu of FARA is not an option “where a foreign government or foreign political party is the principal beneficiary.²¹ Given that Nord Stream 2 is primarily owned by the Russian government’s energy giant Gazprom—whose lobbyists have previously registered under FARA²²—there’s a direct line to a foreign government beneficiary that would seem to indicate registering under FARA would be appropriate. 

Firms working on behalf of another Russian company, En+ Group, even registered under both FARA and the LDA. Mercury Public Affairs, representing En+ Group, registered under FARA, citing the fact that Oleg Deripaska—a sanctioned Kremlin ally—owns 44.95 percent of the energy firm.²³ Despite this, DCI Group, also representing En+ Group, instead registered under the much less transparent LDA in April 2021.

Regardless of the justification, firms representing Russian interests registering under the LDA while firms representing Ukrainian interests reported their work under FARA created an uneven playing field for transparency. Though the public can easily track the efforts of lobbyists working for Ukrainian interests, much of the work being done by lobbyists for these Russian interests remains opaque.

The Pro-Ukraine lobby by the numbers

The Quincy Institute’s analysis of lobbying filings reveals that Ukraine’s agents were doing an extraordinary amount of work prior to Russia’s February 24 invasion of Ukraine. Specifically, in their 2021 FARA filings, firms reported engaging in 13,541 “political activities”²⁴ on behalf of their Ukrainian clients. To put this in perspective, the Saudi lobby—known for being one of the largest foreign lobbies in D.C.—reported 2,834 contacts, not even a quarter of what Ukraine’s agents have done (table 1).²⁵ Even firms registered under FARA to represent clients in Japan, the top spender on FARA firms,²⁶ reported just 3,209 political activities—again, not even a quarter of the work reported by FARA registrants working on behalf of Ukrainian interests.²⁷ This extraordinary workload was driven by pro-Ukraine lobbyists—several of them former Hill staffers—who were especially adept and zealous at influencing congressional staff and members of Congress.

Table 1: The Pro-Ukraine Lobby’s Political Activities in Perspective

This extraordinary workload, however, was not shared evenly across firms representing the pro-Ukraine lobby. In fact, just one firm, Yorktown Solutions, accounted for more than 91 percent of all political activities reported by the pro-Ukraine lobby.²⁸

Table 2: The Most Active Firms Representing Ukraine in the U.S. in 2021

As Table 2 indicates, the range of political activities reported by firms working for Ukrainian interests was immense and dominated by Yorktown Solutions’ 12,400 reported political activities. Yorktown Solutions was paid more than a million dollars in 2021 for an all-encompassing campaign to influence Congress, the media, and think tanks on behalf of its clients, the Civil Movement for a Just Ukraine and the Ukrainian Federation of Employers of the Oil and Gas Industry (UFEOGI).

Yorktown’s work for UFEOGI—the largest association of energy companies in Ukraine²⁹—began in early 2020 with a $960,000 per annum contract, according to which Yorktown agreed to provide “outreach to U.S. government officials, media, and relevant private sector organizations,” in hopes of “safeguarding Ukraine’s energy security and independence.”³⁰ Since then Yorktown has seemingly worked tirelessly on UFEOGI’s behalf, delivering more than 10,000 emails, phone calls, and meetings at the relatively low price of not even $1 million per year. UFEOGI also hired several other firms listed in Table 2—specifically, Karv Communications, ETS Consulting, and Arent Fox.

In August 2021 Yorktown began work on behalf of the Civil Movement for a Just Ukraine “a non-profit organization whose activities: (1) promote the de-oligarchization of Ukraine; (2) support the reform process in Ukraine, especially in the areas of judicial reform, security sector reform, anti-monopolization, and corporate governance; and (3) advance the image of Ukraine and its official institutions,” according to a Yorktown FARA filing.³¹

With more than 13,000 political activities reported in 2021, the pro-Ukraine lobby was able to devote considerable attention to a number of key fields that serve to shape U.S. foreign policy and public opinion. Table 3 breaks down the pro-Ukraine lobby’s work, providing a list of the types of organizations most contacted by these foreign agents.

Table 3: Organizations Contacted Most by Ukraine’s Agents

As Table 3 indicates, Congress was, by far, the primary focus of FARA registrants working on behalf of Ukrainian interests, followed by the media, think tanks, and the State Department. Between the House and Senate, members of Congress and their staff were contacted an astounding 8,422 times by the pro-Ukraine lobby. On at least 235 different days in 2021 Ukraine’s lobbyists reached out to Congressional contacts—more days than Congress was in session in 2021. The pro-Ukraine lobby’s congressional advocacy was not distributed evenly throughout the year and was, instead, focused on dates surrounding key developments. For example, the busiest day for the pro-Ukraine lobby’s Hill outreach was May 21, 2021, the day after the Biden administration announced it was lifting sanctions on the Nord Stream 2 pipeline.³²

The issues

This section discusses the issues behind the lobbying and influence battle between pro-Ukraine and pro-Russia interests. Most firms representing Ukrainian interests focused almost exclusively on the Nord Stream 2 pipeline and security concerns related to Russia, including U.S. military support. Firms representing Russian interests were similarly focused on these pressing issues along with concerted efforts to avoid or minimize sanctions for their clients.

The Nord Stream 2 pipeline

Nord Stream 2 is an energy pipeline that was aimed to transport Russian natural gas to Germany, but in the wake of Russia’s invasion of Ukraine, Germany announced it would not allow the pipeline to become operational. Throughout 2021, however, every indication was that the pipeline would ultimately be up and running, allowing Russia to deliver natural gas directly to Europe, costing Ukrainian energy companies billions in transit revenue every year. 

Unsurprisingly, Russian interests, most notably firms representing Nord Stream 2 AG, lobbied aggressively to stymie any U.S. efforts to block the pipeline. Altogether, firms representing the company spent $3.29 million in 2021 to influence the U.S. position on the pipeline. 

Nord Stream 2 AG doled out $870,000 of this to BGR Government Affairs to lobby on issues “related to the U.S. position toward the Nord Stream 2 pipeline.”³³ But the lion’s share of Nord Stream 2 AG’s spending went to the government affairs firm Roberti Global, which received $2.42 million to lobby against potential financial sanctions and other adverse actions against the pipeline. The chief lobbyist working to further Nord Stream 2 AG’s interests was Vin Roberti, whose bio boasts a quote from GQ magazine describing him as the “Hollywood ideal of a Washington power broker.” Until Russia’s invasion of Ukraine, Roberti’s firm mostly lived up to this hype, with Nord Stream 2 AG overcoming an active opposition lobby to see sanctions lifted in the early months of the Biden administration and construction of the controversial pipeline completed in September of 2021. 

In early 2022, however, Nord Stream 2 AG came under increased scrutiny as Russian troops amassed near the Ukrainian border. Senator Ted Cruz (R-TX) attempted to place immediate sanctions on the pipeline company, though his efforts narrowly failed.³⁴ Senator Bob Menendez (D-NJ) proposed an alternative, which labeled the pipeline a “tool of malign influence” and directed the White House to review its sanctions policy towards Nord Stream 2.³⁵

It is worth noting that both senators have direct ties to pro-Ukraine lobbyists. Yorktown Solutions is headed by Daniel Vajdich, who was previously Senator Ted Cruz’s (R-TX) senior national security advisor on issues related to Russia. When Cruz’s Nord Stream 2 sanctions bill came under fire from the Biden administration, which argued it was “designed to undermine the unity of our allies, not punish Russia,”³⁶ Vajdich quickly responded with a “facts on the ground” brief sent to the office of nearly every Senate Democrat and half of Senate Republicans, debunking the administration’s talking point.³⁷ All told, Yorktown has distributed at least 24 unique informational materials that promote Cruz’s stance on Nord Stream 2, all while Cruz’s former employee, Vajdich, has been at the helm.³⁸

Brittany Beaulieu, another Yorktown lobbyist, was previously a staffer for Senator Bob Menendez (D-NJ). Yorktown has distributed at least 23 separate FARA filings promoting Menendez’s tweets, statements, and quotes since Beaulieu began working for Ukrainian interests. In one instance, for example, Beaulieu distributed a tweet from Menendez that said Nord Stream 2 “should be stopped” and will “negatively impact the security of Ukraine.”³⁹

With this momentous pressure from pro-Ukraine lobbyists, there was a significant uptick in lobbying efforts on behalf of Nord Stream 2 in 2022, prior to the Russian invasion of Ukraine. Roberti Global received $1.21 million in the first quarter of 2022 alone, almost twice as much as it received in the previous quarter.⁴⁰ BGR, meanwhile, received $420,000, twice as much as the previous quarter.⁴¹ The pipeline company’s attempts to curb mounting opposition came to a screeching halt, however, following the February 24 invasion of Ukraine. Both firms were legally required to end their contracts with Nord Stream 2 AG as the company, its CEO, and top corporate officers were all sanctioned by the U.S.⁴²

Much of the lobbying done on behalf of Nord Stream 2 is unknown, given the previously mentioned choice these firms made to register under the LDA. The clear ties between Nord Stream 2 and the Russian government seem to indicate that lobbyists for the pipeline should have registered with FARA; Ukrainian interests, meanwhile, were all registered under FARA and their filings provide a glimpse into an extraordinarily active influence campaign.

The pro-Ukraine lobby and the Ukrainian government made the Nord Stream 2 pipeline synonymous with Ukrainian national security. Foreign agents working on behalf of the Ukrainian Federation of Employers of the Oil and Gas Industry (UFEOGI), specifically, have made the case for why the U.S. and its allies should take a stronger stance against Nord Stream 2. According to some estimates, the companies UFEOGI represents could lose more than $2 billion in transit fees annually on gas passing through Ukraine.⁴³

In hopes of making sure this did not come to pass, UFEOGI hired four lobbying and public relations firms to make the case for opposing the pipeline: Yorktown Solutions, Karv Communications, ETS Consulting, and Arent Fox. The lobbying firms took different strategies for mounting opposition to the pipeline. Arent Fox, for example, had lunch meetings with a State Department contact and a call with the Senate Foreign Relations Committee’s staff director for “intel gathering on Nord Stream 2 pipeline,” according to an Arent Fox FARA filing.⁴⁴ Karv Communications implemented a public media strategy, arranging at least eight interviews between UFEOGI leadership and major media outlets including the Wall Street Journal, Reuters, and CNBC.⁴⁵

FGH Holdings, previously the Glover Park Group, also contacted congressional offices more than 240 times, including sharing documents, “urging the U.S. Congress to use all means available to prevent the construction of the Nord Stream 2 gas pipeline, including the maintenance of sanctions against commercial interests involved in the project,” as one FARA filing explained.⁴⁶

Yorktown Solutions, however, made the lion’s share of contacts. The firm contacted congressional offices, think tanks, media outlets, and several government agencies, including the State Department and Department of Energy discussing “U.S.-Ukraine Energy Issues,” more than 12,000 times. This extraordinary influence operation largely followed major events in U.S.-Ukraine relations. 

This campaign began to kick into high gear on the last day of Donald Trump’s presidency, when he placed sanctions on the Russian pipe-laying ship Fortuna. The move was applauded by UFEOGI, with Yorktown distributing one article that read “Ukraine welcomes U.S. sanctions against Nord Stream 2.”⁴⁷ Meanwhile, the move was met with protests from the pro-Russia lobby, which circulated a statement from the Russian ambassador citing violations of international law.⁴⁸ On May 20, however, Biden’s State Department waived sanctions on Nord Stream 2 AG, the company constructing the pipeline. This sparked furious opposition from Yorktown, including wide circulation of an article headlined, “Why Biden’s Nord Stream 2 sanctions waiver directly threatens Ukraine.”⁴⁹ As a result of Yorktown’s efforts, May 21 was the pro-Ukraine lobby’s single busiest day in congressional outreach.

The rationale behind supporting Nord Stream 2 sanctions frequently shifted along with the news cycle, before the project was effectively blocked in the wake of Russia’s invasion. Amid the arrest of Russian dissident Alexei Navalny in January of 2021, for example, Yorktown disseminated a series of pieces that saw Navalny’s arrest as proof that Nord Stream 2 should be sanctioned. One piece congratulated the U.S. for recognizing “the true nature of this pipeline project” and the European Parliament for voting to demand a halt to construction with a resolution on the arrest of Navalny.⁵⁰ Similarly, when Belarus forced a Ryanair Flight 4978 to land in Minsk, where security forces arrested Roman Protasevich, an opposition journalist in exile who was a passenger on the Vilnius-bound plane, pro-Ukraine lobbyists renewed their calls for sanctions because the Lukashenko regime is backed by Russia. In the wake of the scandal, Yorktown distributed media calling for sanctions on Nord Stream 2, including a tweet from a Belarusian opposition group and a press release from Senator Ben Sasse (R-NE).⁵¹

With Russia announcing that Nord Stream 2 was 99 percent complete in late July, the argument against the pipeline then placed stronger emphasis on Ukraine’s national security and, even then, pointed toward the potential for a Russian invasion. The chairperson of the Verkhovna Rada (parliament) of Ukraine, Dmytro Razumkov, sent a letter to Speaker of the House Nancy Pelosi arguing that the “commissioning of this project will make it possible for Russia to further increase its aggression against Ukraine and potentially against other European states.”⁵² With Ukrainian President Volydymr Zelensky visiting the White House in early September and Germany starting the certification process for the pipeline, Yorktown distributed a Wall Street Journal article on the efforts of Senate Republicans to block Treasury nominations until the Russian firm managing Nord Stream 2 was sanctioned.⁵³ The article was co-authored by Brett Forrest, who has written extensively about Nord Stream 2 and tensions between Russia and Ukraine, and was contacted more than 100 times by Yorktown Solutions on behalf of UFEOGI. The sanctions effort Forrest was writing about was led by Ted Cruz, whose office was contacted hundreds of times by Yorktown’s agents. 

Then, in late 2021 and early 2022, with Russian troops massing on the border with Ukraine, the firms representing UFEOGI began working overtime to emphasize a link between Nord Stream 2 and Ukrainian security. Daniel Vajdich of Yorktown Solutions, for example, distributed a tweet from the prime minister of Ukraine, in which he argued that Nord Stream 2 was “no less an existential threat to our security & democracy than Russian troops on our border.”⁵⁴ This sentiment was echoed, nearly verbatim, two days later by Senator Ted Cruz, Vajdich’s former boss, who said he was hoping to “lift the existential threat posed by Nord Stream 2.”⁵⁵

Another email distributed to journalists by Karv Communications says that “it was in the aftermath of President Biden’s decision not to impose sanctions on Nord Stream 2, that Russia accelerated its aggressive behavior.”⁵⁶ A paper distributed by Yorktown to congressional offices warned that a failure to impose sanctions on Nord Stream 2, “rewards Russia for its military hostility and for threatening Ukraine.”⁵⁷ Many of these informational materials accuse Putin of using “energy as a geopolitical weapon.”⁵⁸

Firms representing UFEOGI welcomed the pushback and sanctions on Nord Stream 2 imposed after Russia’s invasion. KARV Communications, for example, distributed a statement from the CEO of a state-owned Ukrainian energy company welcoming Germany’s decision “to withdraw the official assessment that Nord Stream 2 has no impact on security of gas supply in Germany.”⁵⁹ Energy was discussed more than 12,000 times in emails, calls, and meetings by the pro-Ukraine lobby.⁶⁰

U.S. military support and NATO

While Nord Stream 2 and energy concerns were, by far, the dominant focus of the pro-Ukraine lobby in 2021, some lobbying and public relations efforts were directed at securing U.S. military support and the prospect of Ukraine joining NATO. 

Between 2014 and 2021, the U.S. committed $2.7 billion to support Ukraine’s military, including $721 million to the State Department’s Foreign Military Financing (FMF) and $1.35 billion to the Department of Defense’s Ukraine Security Assistance Initiative.⁶¹ The U.S. has tied some of this security assistance to anti-corruption efforts in Ukraine, including military command reform, transparency, and “transition to a western-style human resources management system,” according to the Department of Defense.⁶² Yorktown Solutions, representing the Civil Movement for a Just Ukraine, a nonprofit whose primary goal is de-oligarchization, distributed an article arguing that military success is tied to anti-corruption.⁶³ Andrew Mac, who is registered under FARA to represent Ukraine’s president, Volodymyr Zelensky, also distributed an article in which he is quoted saying that “there is no daylight between President Zelensky and the United States when it comes to de-oligarchization.”⁶⁴

Much of the lobbying for increased military support for Ukraine occurred just before President Zelensky’s visit to the White House in late August. One Wall Street Journal article written by Michael McFaul, a former ambassador to Russia, and distributed by Yorktown, argues that Biden should “announce major new military assistance” including “anti tank Javelins as well as upgraded radars.”⁶⁵ Andrew Mac also distributed an article that quotes him saying “the situation in Afghanistan seems to indicate realignment of U.S. global commitments, and President Zelensky wants to hear from President Biden where Ukraine fits in.”⁶⁶

Think tanks also played a central role in the pro-Ukraine lobby’s push for U.S. military support, with nearly 600 reported contacts with the Atlantic Council, which has often called for greater U.S. military support for Ukraine. The pro-Ukraine lobby’s engagement with the Atlantic Council included multiple meetings with John Herbst, former U.S. ambassador to Ukraine, who, prior to the Russian invasion, told NPR that President Joe Biden should “send more weapons to Ukraine now.” He added: “By all means, get additional U.S. and NATO forces up along Russia’s border,”⁶⁷ words that seemed to advocate a more direct confrontation between U.S. and Russian forces. 

The Atlantic Council also houses “UkraineAlert” which publishes daily pieces on deterring Russia, including a survey from earlier this year in which the authors argue that the “western public backs stronger support for Ukraine against Russia.”⁶⁸ While the authors note the survey in question was commissioned by the Victor Pinchuk Foundation and Yalta European Strategy, which Pinchuk founded, they fail to mention that the foundation is a significant contributor to the Atlantic Council, donating $250,000–$499,000 per year.⁶⁹ They also neglect to mention that Pinchuk himself—the second wealthiest man in Ukraine—is on the international advisory board of the Atlantic Council.⁷⁰

The Atlantic Council also counts Daniel Vajdich, president of Yorktown Solutions, among its non-resident senior fellows.⁷¹ Yet, nowhere on the Atlantic Council’s website is it noted that Vajdich is a registered foreign agent working on behalf of Ukrainian interests.

NATO also featured prominently in FARA filings from Ukraine’s lobbyists. One open letter written by Ukrainian civil society representatives and distributed by Yorktown writes that “by working together we are nearing the moment of Ukraine’s accession to full membership in NATO.”⁷² In a Politico article, distributed by Ukraine’s lobbyists, the Polish foreign minister, Zbigniew Raw, writes that Poland “remains an unwavering advocate of Ukraine’s membership.”⁷³ Yorktown also distributed a joint statement released by Menendez and his European counterparts saying that “we also need to commit to delivering a road map for Ukraine’s path towards joining the NATO alliance, if Ukraine makes the necessary reforms and meets NATO membership standards.”⁷⁴

In most cases, however, NATO membership played second fiddle to the Nord Stream 2 pipeline, which was almost always at centerstage. An August 21 New York Times article distributed by Yorktown encapsulates this hierarchy of priorities. The headline warns in large text that “It’s now or never. Biden Must Stop Putin’s Beloved Pipeline.” In the text below, in between a larger discussion of Nord Stream 2, the author mentions that “after thanking President Biden for America’s continued support and assistance, the Ukrainian leader may gently inquire about NATO membership.”⁷⁵

The pro-Ukraine lobby’s prioritization of energy concerns over hard security issues was completely flipped when Putin ordered the Russian army to invade Ukraine. Following the invasion, Germany announced it would not certify the Nord Stream 2 pipeline, while Biden announced sanctions on the company and said the U.S. would stop buying oil and gas from Russia. 

With this major win in hand, the pro-Ukraine lobby quickly went from focusing on “energy security to security,” as Vajdich described the pro-Ukraine lobby’s new focus on obtaining U.S. military support for Ukraine’s war with Russia.⁷⁶ This advocacy push, aided immensely by President Zelensky, also met with phenomenal success when Congress and Biden approved tens of billions of dollars in military aid to Ukraine.⁷⁷

Russia sanctions

The goal of many firms working for Russian interests was to prevent or lessen the impact of sanctions on their foreign clients. Most notably, this included the fevered battle over sanctions on the Nord Stream 2 pipeline. However, a variety of Russian energy and banking firms also hired D.C. lobbying and public relations firms to provide sanctions relief.

This past January, for example, Sovcombank was listed as a potential sanctions target in Senator Menendez’ bill,⁷⁸ leading Russia’s ninth-largest bank to hire Mercury Public Affairs.⁷⁹ Mercury deployed two former Members of Congress to lobby on the bank’s behalf: former senator David Vitter (R-LA) and former representative Toby Moffett (D-CT).⁸⁰ In one letter to congressional offices, Senator Vitter wrote that Sovcombank would be an “extremely counterproductive sanctions target” because of its “deep ties to US and western institutions,”⁸¹ and Mercury Public Affairs distributed a 28-slide powerpoint on Sovcombank to go along with it.⁸² Vitter emphasized the bank’s ties to the west while neglecting to mention that the Russia-China investment fund is a major foreign investor in Sovcombank and holds an observer seat on the supervisory board.⁸³ Like many Russian entities, Sovcombank was eventually sanctioned following Russia’s invasion, effectively ending their contract with Mercury Public Affairs.⁸⁴

Mercury Public Affairs also represented En+ Group, an energy and metals company with close ties to Kremlin-ally Oleg Deripaska. En+ Group was sanctioned in 2018, but Mercury Public Affairs concocted a proposal for sanctions relief in what they called the “Barker Plan,” in which Deripaska would have to resign as director of En+.⁸⁵ The plan appeared to work, as sanctions on the company were dropped in early 2019.⁸⁶

After this, however, En+ Group decided to keep its lobbying operation in the U.S. running, which would ultimately help the firm respond to a series of crises. The authors of an August 2020 Senate Intelligence Committee report concluded that “Deripaska’s companies, including RUSAL [a subsidiary of En+ Group], are proxies for the Kremlin, including for Russian government influence efforts, economic measures, and diplomatic relations.”⁸⁷ In response, Senator Vitter contacted the Senate Banking Committee multiple times to discuss the intelligence report. Later that year, Bloomberg reported that Deripaska violated the Treasury Department agreement by retaining “significant day-to-day” influence over En+ Group and its subsidiaries.⁸⁸ Around this time, Senator Vitter contacted staffers from the Senate Banking Committee and its chair, Senator Pat Toomey, including setting up a Zoom meeting. In April of 2021, En+ Group brought on a new firm, DCI Group, to lobby on “issues related to trade and trade sanctions, generally and as they may apply to the independent Board and management of EN+ Group.” In an attempt to distance themselves from Deripska, EN+ circulated an article in June of 2021 highlighting that their sanctions delisting will benefit the U.S. economy, arguing “a healthy Rusal means investment and new jobs in the U.S.”⁸⁹

En+ Group was not the only Russian firm worried about U.S. sanctions. Roberti Global, representing Nord Stream AG, lobbied the House and Senate against “potential financial sanctions affecting the project.”⁹⁰ Russian oligarchs Alexander Skorobogatko and Alexander Ponomarenko paid Qorvis Communications $100,000 for lobbying related to sanctions legislation.⁹¹ However, since they registered under the LDA and not FARA, there is less transparency about specific political activities these Russian firms and individuals engaged in.

Key findings

This report has sought to provide the public with a better understanding of the lobbying battle in the U.S. between Russian and Ukrainian interests prior to the February 24 Russian invasion of Ukraine. At that time, key U.S. foreign policy decisions—most notably, the Nord Stream 2 pipeline and the level of U.S. military assistance provided to Ukraine—were still being debated in Washington. While Putin’s decision to invade Ukraine effectively ended the Nord Stream 2 pipeline and led to historic increases in U.S. military support for the Ukrainian military, this report has shown that these outcomes were anything but inevitable. In fact, they were at the heart of a fevered battle between lobbying, public relations, and other firms working for Russian and Ukrainian interests.

Based on an exhaustive analysis of all FARA and LDA documents filed by organizations registered to work on behalf of Ukrainian and Russian clients in 2021,⁹² this report made a number of key findings, including:

• Nine organizations were registered under FARA to work on behalf of Russian clients in 2021, while 11 were working for Ukrainian clients.

• Those organizations reported making just 21 contacts on behalf of their Russian clients and 13,541 contacts on behalf of their Ukrainian clients.

• Russian clients paid over $42 million to firms representing them, (although $38 million of this went to Russian state media), while Ukrainian clients paid just over $2 million to the firms working on their behalf.

• Pro-Ukraine lobbying efforts add up to more than four times the amount of work the Saudi lobby (among the largest foreign lobbies in Washington) and other prominent groups have reported in any year–due in large part to a notable gap in transparency.

• The pro-Ukraine lobby appears to have achieved far more contacts than the pro-Russia lobby with less money spent, an anomaly that could be explained by the pro-Russia lobby using a less transparent statute—the LDA—for reporting its lobbying efforts and the greater zeal shown by some pro-Ukraine lobbyists.

While this analysis focused on 2021, the pro-Ukraine lobby—now operating virtually unopposed as nearly all U.S. firms have severed ties with Russian interests— is still very much seeking to influence U.S. foreign policy and build on their successes. Many of the objectives they sought for years were achieved in 2022. The most notable of these are ending the Nord Stream 2 pipeline, the severing of U.S. ties with the Russian energy sector, and tens of billions of dollars in U.S. military assistance now flowing to Ukraine. The pro-Ukraine lobby continues to push for even more, including further sanctions on Russian interests and more advanced U.S. military equipment,⁹³ including heavy artillery, drones, and anti-aircraft missile systems.⁹⁴ While it remains to be seen if these efforts will meet with continued success, if history is any indication, the pro-Ukraine lobby will undoubtedly continue to work tirelessly to shape U.S. foreign policy for years to come.

Acknowledgements

This report benefited from the data collection and analysis work of Nick Cleveland-Stout and Taylor Giorno. Nick also provided invaluable research assistance and helped draft sections of the report. The report also benefited from comments and conversations with my Quincy Institute colleagues Sarang Shidore, Trita Parsi, Lora Lumpe, Anatol Lieven, and William Hartung.

About the Author

Ben Freeman is a Research Fellow at the Quincy Institute for Responsible Statecraft. His work focuses on how foreign governments seek to influence American government and politics. This work builds upon his book, The Foreign Policy Auction, which was the first book to systematically analyze the foreign influence industry in the U.S. Previously, he was Director of the Foreign Influence Transparency Initiative at the Center for International Policy. His work has appeared in numerous media outlets, including the New York Times, Politico, and CNN, and he has testified before the Senate Armed Services Committee.

Authors

Ben Freeman

Director, Democratizing Foreign Policy Program

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Ben Freeman is Director of the Democratizing Foreign Policy program at the Quincy Institute for Responsible Statecraft. His work focuses on how foreign governments seek to influence American government and politics. This work builds upon his book, The Foreign Policy…

1. Lee, Matthew. “U.S. finds Russian troops have committed war crimes in Ukraine.” AP News, March 23, 2022. https://apnews.com/article/russia-ukraine-biden-europe-antony-blinken-nato-fa0786b41cd876208771017aa1abab13 ↩

2. Sullivan, Rory. “Up to 40,000 Russian casualties in Ukraine, senior NATO official estimates.” Independent, March 23, 2022. https://www.independent.co.uk/news/world/europe/russian-casualty-figures-nato-ukraine-b2042568.html ↩

3. Byfield, Chris. “Russia ‘terrified’ sanctions will cause economic collapse: ‘having an effect.’” Express, March 22, 2022. https://www.express.co.uk/news/world/1584641/russia-sanctions-moscow-ukraine-invasion-vladimir-putin-spt ↩

4. Lieven, Anatol. “Ending the Threat of War in Ukraine: A Negotiated Solution to the Donbas Conflict and the Crimean Dispute.” Quincy Institute, January 4, 2022. https://quincyinst.org/report/ending-the-threat-of-war-in-ukraine/#the-donbas-conflict-and-its-origins ↩

5. Elias, Yousif. “U.S. Military Assistance to Ukraine.” Stimson Center, January 26, 2022. https://www.stimson.org/2022/u-s-military-assistance-to-ukraine/ ↩

6. “Nord Stream 2: How does the pipeline fit into the Ukraine-Russia crisis?” BBC News, February 22, 2022. https://www.bbc.com/news/world-europe-60131520 ↩

7. Pancevski, Bojan and Joe Wallace. “With Nord Stream 2 Freeze, Germany Takes First Step to Cut Russian Gas Reliance.” The Wall Street Journal, February 23, 2022. https://www.wsj.com/articles/with-nord-stream-2-freeze-germany-takes-first-step-to-cut-russian-gas-reliance-11645640316?mod=article_inline ↩

8.  In this report, “pro-Ukraine lobby” is synonymous with the Foreign Agents Registration Act (FARA) registered firms and individuals working on behalf of Ukrainian clients. It encompasses more than just lobbying. As is shown throughout this report, the pro-Ukraine lobby does far more than just lobbying Congress and the Executive branch. It also sought influence at a number of media outlets and think tanks, for example. The “pro-Ukraine lobby” as mentioned in this report also refers to more than just the lobbyists working on behalf of the Ukrainian government. It includes non-governmental organizations in Ukraine also registered under FARA, most notably a trade association representing Ukraine’s energy sector. Similarly, the “pro-Russia lobby” includes firms working for a variety of Russian interests with varying degrees of connectivity to the Russian government. These entities also did far more than just traditional lobbying, including a significant amount of public relations and media work, especially through Russia state media operating in the U.S. ↩

9. Ford, Brody. “Russian Firms Spent Millions on U.S. Lobbying. Now They’re Getting Dumped.” BloombergQuint, March 2, 2022.  https://www.bloombergquint.com/business/russian-firms-are-cut-by-u-s-lobbyists-after-spending-millions ↩

10. Fuchs, Hailey. “Influencers behind the Ukrainian PR machine.” Politico, March 17, 2022. https://www.politico.com/news/2022/03/17/influencers-ukrainian-pr-machine-00018299 ↩

11. Freeman, Ben and William Hartung. “Putting Biden’s new whopping $33B Ukraine package into context.” Responsible Statecraft, April 28, 2022. https://responsiblestatecraft.org/2022/04/28/putting-bidens-new-whopping-33b-ukraine-package-into-context/ ↩

12. Gardner, Timothy, and Richard Cowan. “Cruz’ Nord Stream 2 sanctions bill fails in U.S. Senate.” Reuters, January 13, 2022.   https://www.reuters.com/world/us/us-democrats-slam-cruz-nord-stream-2-sanctions-bill-ahead-vote-2022-01-13/ ↩

13. This is revenue that was reported in 2021 filings. This money may not necessarily have been received in 2021 and may not have been intended to pay for work conducted in 2021. This is because there are no standardized reporting periods for FARA filings. A firm may receive payment for work it has done previously, or for work it is expected to do, and does not have to indicate which is the case in its FARA filings. In this analysis, all spending figures were those reported in 2021 FARA filings, unless otherwise noted. ↩

14. Josh Gerstein. “DOJ told RT to register as foreign agent partly because of alleged 2016 election interference,” Politico, November 21, 2017. https://www.politico.com/story/2017/12/21/russia-today-justice-department-foreign-agent-election-interference-312211 ↩

15. All of these documents are publicly available and can be found on the FARA or LDA websites at: https://www.justice.gov/nsd-fara and  https://lda.senate.gov/system/public/ ↩

16. Because FARA does not have fiscal years or standardized reporting periods, and the Supplemental Statements, which contain much of this information, cover a six-month reporting period, some of the political activities and contributions reported in 2020 occurred in late 2019. Similarly, some of the activities and contributions that occurred in late 2020 will only be reported in the first half of 2021. ↩

17. This report does not address illicit influence operations conducted by the Russian government or other Russian interests, such as those used to meddle in U.S. elections. While it is likely similar tactics are, or have been, employed surrounding the crisis in Ukraine, the full extent of these Russian efforts is not yet known and is thus beyond the scope of this analysis. ↩

18. Lauer, Jay Matthew. “Supplemental Statement.” Department of Justice, November 30, 2021. 

     https://efile.fara.gov/docs/6739-Supplemental-Statement-20211130-4.pdf and 

    Sidley Austin LLP. “Supplemental Statement.” Department of Justice, November 30, 2021. ↩

19. “Department of Justice.” U.S. Government Publishing Company. July 1, 2016 Edition. https://www.govinfo.gov/content/pkg/CFR-2016-title28-vol1/pdf/CFR-2016-title28-vol1-part5.pdf  ↩

20. “Title 22—Foreign Relations and Intercourse.” U.S. Government Publishing Company, 2010 Edition.  https://www.govinfo.gov/content/pkg/USCODE-2009-title22/pdf/USCODE-2009-title22-chap11-subchapII.pdf  ↩

21. “Department of Justice.” U.S. Government Publishing Company. July 1, 2016 Edition. https://www.govinfo.gov/content/pkg/CFR-2016-title28-vol1/pdf/CFR-2016-title28-vol1-part5.pdf  ↩

22.  Gavin Anderson & Company. “Exhibit A to Registration Statement.” Department of Justice, August 7, 2007. https://efile.fara.gov/docs/5824-Exhibit-AB-20070809-1.pdf ↩

23. Mercury Public Affairs. “Exhibit A to Registration Statement.” Department of Justice, March 26, 2020. https://efile.fara.gov/docs/6170-Exhibit-AB-20200326-81.pdf ↩

24. FARA requires registered foreign agents to report all of their “political activities,” which the statute defines broadly to include anything that will, “influence any agency or official of the government of the United States or any section of the public within the United States with reference to…the domestic or foreign policies of the United States or with reference to the political or public interests, policies, or relations of a government of a foreign country or a foreign political party.” This covers much of the lobbying and public relations work FARA registrants do on behalf of their foreign clients. Thus, collectively, the reports of these activities provide a fairly comprehensive picture of what a country’s FARA registered agents are doing in America, and what issues matter to them. ↩

25. Freeman, Ben. “The Saudi Lobby in 2020.” Center for International Policy, May, 2021. https://3ba8a190-62da-4c98-86d2-893079d87083.usrfiles.com/ugd/3ba8a1_a3f4d1858a9d4afb96f019a206573810.pdf ↩

26. “Foreign Lobby Watch.” OpenSecrets. https://www.opensecrets.org/fara ↩

27. Freeman, Ben. “Japan’s Influence in America.” Center for International Policy, November, 2020. https://3ba8a190-62da-4c98-86d2-893079d87083.usrfiles.com/ugd/3ba8a1_7803e3925ccf4282a68ee9b310e2515b.pdf

    To be sure, many factors can influence the total number of reported political activities referenced here–not the least of which is the varying levels of transparency across firms registered under FARA. And, with Ukraine, as with Saudi Arabia and Japan, some activities may go unreported. Nonetheless, this discrepancy between the reported activities of Ukrainian interests and those of other countries is remarkable. ↩

28. Political activities are primarily reported in FARA Supplemental Statements, which are filings made every six-months. Given that these filings are not required until six months after a firm first registered under FARA some firms that began work on behalf of Ukrainian clients in the second half of 2021 have yet to file Supplemental Statements. This includes, for example, Asters Consult and Quinn Emanuel Urquhart & Sullivan, both of whom registered under FARA in November to represent The Ministry of Finance of Ukraine. ↩

29. UIA “FEOGI.” “Ukrainian Industry Association ‘Federation of Employers of the Oil and Gas Industry’ (UIA ‘FEOGI’) is the largest association of the oil and gas enterprises in Ukraine.” UFEOGI, 2018. https://frng.org.ua/en/pro-nas/frnh ↩

30. Yorktown Solutions, LLC. “Exhibit B to Registration Statement.” Department of Justice, January 5, 2020.  https://efile.fara.gov/docs/6491-Exhibit-AB-20200105-14.pdf ↩

31. Yorktown Solutions, LLC. “Exhibit A to Registration Statement.” Department of Justice. August 17, 2021. https://efile.fara.gov/docs/6491-Exhibit-AB-20210817-19.pdf ↩

32. “Nord Stream 2: Biden waives U.S. sanctions on Russian pipeline.” BBC, May 20, 2021.  https://www.bbc.com/news/world-us-canada-57180674 ↩

33. Roberti Global. “Registration” Lobbying Disclosure Act of 1995, August 11, 2017 https://lda.senate.gov/filings/public/filing/23a7c4fc-fd15-4e76-970f-785f8a322402/print/ ↩

34. Sen. Cruz on Upcoming Nord Stream 2 Vote: The Eyes of History Are upon Us.” Senator Ted Cruz, January 13, 2022. https://www.cruz.senate.gov/newsroom/press-releases/sen-cruz-on-upcoming-nord-stream-2-vote-the-eyes-of-history-are-upon-us ↩

35. ROS22031 JMY S.L.C. – Foreign.senate.gov.” https://www.foreign.senate.gov/imo/media/doc/ROS22031.pdf. ↩

36. The White House. “The Cruz Bill is Designed to Undermine the Unity of our Allies, not Punish Russia.” Politico, January, 2022. https://www.politico.com/f/?id=0000017e-4faa-dbc8-a1ff-7fab7a270000 ↩

37. Ward, Alexander and Quint Forgey. “The dueling lobbying campaigns on Cruz’s NS2 bill.” National Security Daily, Politico, January 12, 2022. https://www.politico.com/newsletters/national-security-daily/2022/01/12/the-dueling-lobbying-campaigns-on-cruzs-ns2-bill-495703 ↩

38. According to a Quincy Institute analysis of FARA Informational Materials filed by Yorktown Solutions and available at the FARA website: https://efile.fara.gov/ords/fara/f?p=1235:10 ↩

39. Yorktown Solutions, LLC. “Informational Material.” Department of Justice, August 5, 2021.  https://efile.fara.gov/docs/6491-Informational-Materials-20210805-337.pdf ↩

40. Roberti Global. “1st Quarter Report.” Lobbying Disclosure Act of 1995, April 17, 2022 https://lda.senate.gov/filings/public/filing/4e8823ab-fc29-4041-ac36-37d21fd4205f/print/ ↩

41.  BGR Government Affairs. “1st Quarter Report-Termination.” Lobbying Disclosure Act of 1995, February 24, 2022 https://lda.senate.gov/filings/public/filing/9279043c-1adc-4f2d-aeaa-05bb6d73d739/print/ ↩

42. “Sanctioning NS2AG, Matthias Warnig, and NS2AG’s Corporate Officers – United States Department of State.” U.S. Department of State, February 24, 2022. https://www.state.gov/sanctioning-ns2ag-matthias-warnig-and-ns2ags-corporate-officers/. ↩

43. “Nord Stream 2: How does the pipeline fit into the Ukraine-Russia crisis?” BBC, February 22, 2022. https://www.bbc.com/news/world-europe-60131520 ↩

44. Arent Fox LLP. “Supplemental Statement.” Department of Justice, November 30, 2021. https://efile.fara.gov/docs/6952-Supplemental-Statement-20211130-1.pdf ↩

45. Yorktown Solutions. “Supplemental Statement.” Department of Justice, November 30, 2021. https://efile.fara.gov/docs/6491-Supplemental-Statement-20211227-8.pdf ↩

46. FGH Holdings. “Informational Material.” Department of Justice, May 24, 2021.  https://efile.fara.gov/docs/5666-Informational-Materials-20210524-54.pdf ↩

47. Yorktown Solutions LLC. “Informational Material.” Department of Justice, January 20, 2021. https://efile.fara.gov/docs/6491-Informational-Materials-20210120-180.pdf ↩

48. Ghebi LLC. “Informational Material.” Department of Justice, January 20, 2021. https://efile.fara.gov/docs/6869-Informational-Materials-20210120-99.pdf ↩

49. Yorktown Solutions LLC. “Informational Material.” Department of Justice, June 2, 2021. https://efile.fara.gov/docs/6491-Informational-Materials-20210602-262.pdf ↩

50. Yorktown Solutions LLC. “Informational Material.” Department of Justice, April 16, 2021. https://efile.fara.gov/docs/6491-Informational-Materials-20210416-229.pdf ↩

51.  Yorktown Solutions LLC. “Informational Material.” Department of Justice, May 25, 2021. https://efile.fara.gov/docs/6491-Informational-Materials-20210525-256.pdf ↩

52. Yorktown Solutions LLC. “Informational Material.” Department of Justice, August 5, 2021. https://efile.fara.gov/docs/6491-Informational-Materials-20210805-344.pdf ↩

53. Yorktown Solutions LLC. “Informational Material.” Department of Justice, September 15, 2021. https://efile.fara.gov/docs/6491-Informational-Materials-20210915-420.pdf ↩

54. Yorktown Solutions LLC. “Informational Material.” Department of Justice, January 11, 2022. https://efile.fara.gov/docs/6491-Informational-Materials-20220111-577.pdf ↩

55. Gardner, Timothy and Richard Cowan. “Cruz’s Nord Stream 2 sanctions bill fails in U.S. Senate.” Reuters, January 13, 2022. https://www.reuters.com/world/us/us-democrats-slam-cruz-nord-stream-2-sanctions-bill-ahead-vote-2022-01-13/ ↩

56. KARV Communications. “Informational Material.” Department of Justice, January 14, 2022. https://efile.fara.gov/docs/6162-Informational-Materials-20220114-18.pdf ↩

57. Yorktown Solutions LLC. “Informational Material.” Department of Justice, January 12, 2022. https://efile.fara.gov/docs/6491-Informational-Materials-20220112-580.pdf ↩

58. Yorktown Solutions LLC. “Informational Material.” Department of Justice, November 6, 2021. https://efile.fara.gov/docs/6491-Informational-Materials-20211106-512.pdf ↩

59.  KARV Communications. “Informational Material.” Department of Justice, February 23, 2022.  https://efile.fara.gov/docs/6162-Informational-Materials-20220223-19.pdf ↩

60.  According to a Quincy Institute analysis of FARA “Supplemental Statements” made by firms working on behalf of Ukrainian interests and available from the Department of Justice at the FARA website: https://www.justice.gov/nsd-fara ↩

61. Bureau of Political-Military Affairs, Department of State. “U.S. Security Cooperation with Ukraine Fact Sheet.” Department of State, March 3, 2022. https://www.state.gov/u-s-security-cooperation-with-ukraine/#:~:text=Since%202014%2C%20%E2%80%8Bthe%20U.S.,and%20improve%20interoperability%20with%20NATO. ↩

62. U.S. Department of Defense Press Release. “DOD Announces $250M to Ukraine.” U.S. Department of Defense, June 11, 2022. ​​https://www.defense.gov/News/Releases/Release/Article/2215888/dod-announces-250m-to-ukraine/ ↩

63. Yorktown Solutions LLC. “Informational Material.” Department of Justice, February 7, 2022.  https://efile.fara.gov/docs/6491-Informational-Materials-20220207-585.pdf ↩

64. Mac, Andrew. “Informational Material.” Department of Justice, March 17, 2021.  https://efile.fara.gov/docs/6750-Informational-Materials-20210317-1.pdf ↩

65. Yorktown Solutions LLC. “Informational Material.” Department of Justice, August 30, 2021. https://efile.fara.gov/docs/6491-Informational-Materials-20210830-384.pdf ↩

66. Yorktown Solutions LLC. “Informational Material.” Department of Justice, August 30, 2021.  https://efile.fara.gov/docs/6491-Informational-Materials-20210830-370.pdf ↩

67. Morning Edition. “Would a push by the U.S. military deter Russia from invading Ukraine?” NPR, January 24, 2022. https://www.npr.org/2022/01/24/1075264780/would-a-push-by-the-u-s-military-deter-russia-from-invading-ukraine ↩

68. Bildt, Carl, Aleksander Kwasniewski, Victor Pinchuk, Anders Fog Rasmussen. “Survey: Western public backs stronger support for Ukraine against Russia.” Atlantic Council, January 25, 2022. https://www.atlanticcouncil.org/blogs/ukrainealert/survey-western-public-backs-stronger-support-for-ukraine-against-russia/ ↩

69. “Honor roll of contributions.” Atlantic Council. https://www.atlanticcouncil.org/about/donate/honor-roll-of-contributors-2019/ ↩

70. “International advisory board.” Atlantic Council.  https://www.atlanticcouncil.org/about/international-advisory-board/ ↩

71. Profile of Daniel Vajdich. Atlantic Council. https://www.atlanticcouncil.org/expert/daniel-vajdich/ ↩

72. Yorktown Solutions LLC. “Informational Material.” Department of Justice, December 19, 2022. https://efile.fara.gov/docs/6491-Informational-Materials-20211219-557.pdf ↩

73. Yorktown Solutions LLC. “Informational Material.” Department of Justice, February 23, 2021. https://efile.fara.gov/docs/6491-Informational-Materials-20210223-202.pdf ↩

74.  Yorktown Solutions LLC. “Informational Material.” Department of Justice, August 5, 2021. https://efile.fara.gov/docs/6491-Informational-Materials-20210806-326.pdf ↩

75. Yorktown Solutions LLC. “Informational Material.” Department of Justice, August 30, 2021. https://efile.fara.gov/docs/6491-Informational-Materials-20210830-378.pdf ↩

76. Fuchs, Hailey. “Influencers behind the Ukrainian PR machine.” Politico, March 17, 2022. https://www.politico.com/news/2022/03/17/influencers-ukrainian-pr-machine-00018299 ↩

77. Freeman, Ben and William Hartung. “Putting Biden’s new whopping $33B Ukraine package into context.” Responsible Statecraft, April 28, 2022.  https://responsiblestatecraft.org/2022/04/28/putting-bidens-new-whopping-33b-ukraine-package-into-context/ ↩

78. As Threat of Russian Invasion of Ukraine Looms, Menendez Leads Senate Democrats in Introducing the Defending Ukraine Sovereignty Act of 2022.” United States Senate Committee on Foreign Relations, January 12, 2022. https://www.foreign.senate.gov/press/chair/release/as-threat-of-russian-invasion-of-ukraine-looms-menendez-leads-senate-democrats-in-introducing-the-defending-ukraine-sovereignty-act-of-2022. ↩

79. Mercury Public Affairs LLC. “Exhibit A to Registration Statement.” Department of Justice, January 27, 2022. https://efile.fara.gov/docs/6170-Exhibit-AB-20220127-106.pdf ↩

80. Vitter, David. “Short Form Registration Statement.” Department of Justice, January 27, 2022. https://efile.fara.gov/docs/6170-Short-Form-20220127-758.pdf ↩

81. Mercury Public Affairs LLC. “Informational Material.” Department of Justice, February 8, 2022. https://efile.fara.gov/docs/6170-Informational-Materials-20220208-1088.pdf ↩

82. Sovocombank. “Informational Material.” Department of Justice, February 1, 2022. ↩

83. Mercury Public Affairs LLC. “Exhibit A to Registration Statement.” Department of Justice, January 27, 2022. https://efile.fara.gov/docs/6170-Exhibit-AB-20220127-106.pdf#page=2 ↩

84. “U.S. Treasury Announces Unprecedented & Expansive Sanctions Against Russia, Imposing Swift and Severe Economic Costs.” U.S. Department of the Treasury, February 24, 2022. https://home.treasury.gov/news/press-releases/jy0608 ↩

85. Former Senator Vitter among Foreign Agents Paid to Ease Sanctions on Russian Oligarch’s Firm.” OpenSecrets News, January 17, 2019. https://www.opensecrets.org/news/2019/01/senator-david-vitter-among-foreign-agents-sanctions-on-russian-oligarch/. ↩

86. U.S. Department of the Treasury. https://home.treasury.gov/news/press-releases. ↩

87. United States Senate Select Committee on Intelligence,” n.d. https://www.intelligence.senate.gov/sites/default/files/documents/report_volume5.pdf. ↩

88. Pecquet, Julian. “Russian Oligarch Deripaska’s EN+ Group Taps Dem Strategist for Sanctions Lobbying.” Foreign Lobby, June 7, 2021. https://www.foreignlobby.com/2021/06/02/russian-oligarch-deripaskas-en-group-taps-dem-strategist-for-sanctions-lobbying/. ↩

89. Mercury Public Affairs LLC. “Informational Material” Department of Justice, April 26, 2021. https://efile.fara.gov/docs/6170-Informational-Materials-20210616-956.pdf ↩

90. “Search LD-1 & LD-2 Reports Registrations & Quarterly Activity.” Search Registrations & Quarterly Activity Reports | Lobbying Disclosure. https://lda.senate.gov/filings/public/filing/search/. ↩

91. “Search LD-1 & LD-2 Reports Registrations & Quarterly Activity.” Search Registrations & Quarterly Activity Reports | Lobbying Disclosure. https://lda.senate.gov/filings/public/filing/search/. ↩

92. All of these documents are publicly available and can be found on the FARA or LDA websites at: https://www.justice.gov/nsd-fara and https://lda.senate.gov/system/public/ ↩

93. Fuchs, Hailey. “Influencers behind the Ukrainian PR machine.” Politico, March 17, 2022.   https://www.politico.com/news/2022/03/17/influencers-ukrainian-pr-machine-00018299 ↩

94. Macias, Amanda. “Here’s a look at the $5.6 billion in firepower the U.S. has committed to Ukraine in its fight against Russia.” CNBC.com, June 17, 2022. https://www.cnbc.com/2022/06/17/russia-ukraine-war-summary-of-weapons-us-has-given-to-ukraine.html ↩