Jason Maloni, a Manafort spokesman, refused to go into details about what took Manafort so long to register as a foreign agent. And as Politico pointed out, the filing allows for amendments or changes, leaving open the possibility that Manafort and his firm did even more work for Ukraine. "Unlike Flynn, Paul was not simultaneously working as a foreign agent while he was working for Trump".
The filing shows that Manafort and his business associate Rick Gates, who also worked for the Trump campaign, gave "strategic counsel and advice to members of the Party of Regions regarding their interaction with US government officials and other Western influential persons to advance the goal of greater political and economic integration between the Ukraine and the West".
The filing leaves open the possibility that Manafort did more in Ukraine that he admits in the document.
The filing also reveals that Manafort or Gates met in 2013 with Rep. Dana Rohrabacher (R-Calif.), who is considered Russia's most reliable defender in Congress. Manafort or Gates also met with Paula Dobriansky, a former US official who's now a senior fellow at Harvard's Kennedy School, and Nadia Diuk, a vice president at the National Endowment for Democracy.
However, Maloni made it clear that the two cases should not be compared as Flynn's actions are not the same as Manafort's. The work also included counsel to the European Center for a Modern Ukraine, a nonprofit group that once included members of Mr. Yanukovych's party.
The disclosures show much of the work Manafort focused on the Party of Regions in 20120213: implementing election campaign strategies, developing its party platform and conducting worldwide election monitoring.
Manafort served as Trump's campaign chairman from March 2016 to August 2016, but he was forced to resign as he came under increasing scrutiny for his past work consulting for Kremlin-backed former Ukrainian President Viktor Yanukovych.
Manafort's firm spent more than $4 million on consultants, polling, and other services on behalf of the Party of Regions, the documents show.
On Monday, the head of the anti-corruption unit of the Ukrainian's general prosecutor's office said in a television interview in Kiev that his office had "not discovered any evidence proving Manafort's involvement" in ledger payments.
The disclosures cap lengthy negotiations with officials at the Justice Department, which monitors activities of Americans who work on behalf of foreign political parties and governments.
To bring felony criminal charges, however, the DOJ must not only prove that someone acted as a foreign agent without registering but that they knew about having to register and didn't - a high burden of proof to meet.
Rohrabacher, Dobriansky and Diuk didn't immediately respond to requests for comment. According to that report, Manafort and fellow Trump adviser Rick Gates secretly helped funnel money from Yanukovych's party to two Washington lobbying firms in hopes of influencing USA policy.
The emails show Gates directing lobbyists from Washington firm Mercury LLC to set up meetings between a top Ukrainian official and senators and congressmen on influential committees involving Ukrainian interests.
FARA requires so-called foreign agents to register within 10 days of agreeing to conduct work for the foreign entity and to provide updates every six months on political activities.
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