Who is the foreign client for whom Rudy is supposedly trying to affect US policy? If he’s repping Trump, his client isn’t foreign. What US policy is he trying to influence? If it’s to get the investigation of Biden, how is that on behalf of Ukranians?
If he’s trying to get the Ukranians to investigate Biden, how is that influencing US policy? Was he lobbying State Dept & Trump to get rid of Ambassador Yovanovitch on behalf of Ukraine or Ukranians? It was reported that was because he didn’t think she was loyal to Trump.
Just mixing together foreigners, US policy & a client in some kind of combination doesn’t create a FARA violation. The statute requires disclosure that you’re representing foreigners in such a way that you’re influencing US policy through contact w/a federal agency or official.
Some great points made in this twitter thread about Rudy's supposed FARA violation.
https://twitter.com/McAdooGordon/status/1387851677131280390?s=20