Rudy Giuliani has become a regular feature in President Donald Trump’s capital city, attracting scandal — and scrutiny from law enforcement — for his far-flung international endeavors. But unlike his most prominent White House client, Giuliani, who spent more than a dozen years with two well-known K Street firms, has deep ties to the influence industry.

The former New York mayor and onetime Republican presidential candidate logged a decade with the law and lobbying firm then known as Bracewell & Giuliani and a two-year stint after that with Greenberg Traurig, the professional home of notorious ex-lobbyist Jack Abramoff before he went to prison.

Giuliani never registered to lobby and has never disclosed work as a foreign agent, though it’s his international portfolio that has generated attention from federal prosecutors, according to news reports. Recent business associates, U.S. citizens Lev Parnas and Igor Fruman who immigrated from Ukraine, were arrested on campaign finance charges stemming from donations that may have come from prohibited foreign sources.

It’s quite a turn from Giuliani’s stature as mayor of New York City during the 9/11 attacks and the aftermath, when he was affectionately dubbed America’s Mayor.

Giuliani says the recent scrutiny of his work, past and current, amounts to a smear campaign against him because of his high-profile defense of the president, whom House Democrats are moving to impeach. At the center of that impeachment inquiry is Trump’s alleged effort to link U.S. aid to Ukraine with an investigation there into involvement of the president’s political rival, Joe Biden, and his son Hunter.

“Despite all of the contrary, false, Democratic rumors, I have never lobbied for anyone,” Giuliani said in a phone interview with CQ Roll Call on Tuesday. He said he’s refused any such work over the years and estimates he could have made roughly $10 million if he had taken on lobbying projects. He said his work was not subject to the Foreign Agents Registration Act.

“I do not lobby, I do not do foreign representation,” he said.

Most of his former colleagues declined to discuss Giuliani’s roles in their firms, but at Bracewell, as it is now known, he was instrumental in establishing its New York outpost.

“He was never going to be a lobbyist,” former Rep. Jim Chapman, a Texas Democrat and a leader of Bracewell’s lobbying practice when Giuliani joined the firm in 2005, recalled in a recent phone interview.

New York insider

Giuliani’s “sweet spot,” instead, was recruiting “really talented” New York lawyers to the firm’s then-fledgling Manhattan office, said Chapman, who has since retired from the firm. Putting Giuliani’s name on the door gave the Houston-based outfit immediate recognition in New York City.

And what Giuliani got in return was entree to two big fundraising hubs: Washington, D.C., and Texas. While at Bracewell & Giuliani, the former mayor launched a failed bid for the GOP presidential nomination in 2007, an effort that brought him regularly through the nation’s capital, recalled former colleagues and other lobbyists, some of whom donated to his campaign.

Bracewell declined to comment through an outside public relations agency.

Registered federal lobbying clients of then-Bracewell & Giuliani included the FBI Agents Association, NCTA – The Internet & Television Association, Edison Electric Institute, Waste Management and Michaels Stores, among many others, lobbying filings show.

Numerous former clients of Bracewell & Giuliani said they had no memory of Giuliani’s involvement in their lobbying matters.

“No one here has recollections of any interactions with Giuliani,” Brian Dietz, NCTA’s senior vice president of strategic communications, said in an email.

Far-flung interests

In January 2016, 10 months before Trump was elected president, Giuliani left Bracewell and set up shop at Greenberg Traurig, a lobbying and law firm with many offices abroad including in Israel, Germany and Poland. He was based in the firm’s New York office, according to firm spokeswoman Jill Perry.

He was global chairman of Greenberg’s cybersecurity and crisis management practice and said he would house his own ventures — Giuliani Partners and Giuliani Safety & Security — in Greenberg’s offices. All through his time with Bracewell and with Greenberg, Giuliani maintained those two separate businesses.

He said that he did, and continues to do, security work that includes advising cities, states, countries and companies on security: cybersecurity, physical security and bomb detection. He said he also does legal work related to those clients and said he has been a member of the New York bar since 1969. He opened an additional New York-based firm, Rudolph W. Giuliani PLLC, in June.

During Giuliani’s time at Bracewell, and later at Greenberg Traurig, he frequently came to Washington, as well as the firms’ other offices, traveling the world, particularly while at Greenberg Traurig, where, he said, he was “probably their best-known partner.” He also frequently gave speeches, he estimated, in 80 or 90 different countries.

Though Bracewell appears not to have registered to do foreign influence work, Giuliani’s name appears in FARA filings during his time there, according to FARA disclosures first unearthed by NBC News. The National Council of Resistance of Iran noted an Aug. 14, 2014, meeting with “Mayor Rudy Giuliani to discuss Iran’s nuclear weapons as well as Iran’s terrorism in the region, including Iraq and Syria.”

Giuliani told CQ Roll Call he had “no idea” why his name appeared in the filing.

William Minor, a partner with DLA Piper who focuses on lobbying laws, said the foreign agent law is “far more broad than people understand and is not solely concerned with lobbying.”

It includes, for example, efforts to influence segments of the U.S. population, such as financial investors, Minor said. And the exceptions can be narrow, he added.

Still, both the domestic and foreign lobbying regulations “require a pretty specific fact analysis, both to determine whether the law itself applies and whether an exception might be relevant,” Minor said.

“It really defies reason that Giuliani has never registered as a lobbyist” either under the Lobbying Disclosure Act, or FARA, said Public Citizen lobbyist Craig Holman.

Ukraine scandals

Giuliani’s possible work for Ukrainian interests has become the subject of a federal probe, according to news reports including in The New York Times. Giuliani is himself a former federal prosecutor.

For its part, Greenberg Traurig does disclose foreign lobbying work. In its latest foreign agent filing to the Justice Department, Greenberg’s foreign clients included Turkey.

Giuliani left Greenberg Traurig in May 2018, as his defense of Trump became increasingly public with regular, and frequently controversial, television appearances amid the then-ongoing special counsel probe of Russian interference in the 2016 elections. The firm did not respond to an inquiry about the circumstances of his departure, though some insiders say they believe Giuliani was asked to leave.

K Street headhunter Ivan Adler, who runs Ivan Adler Associates, said he didn’t have knowledge of Giuliani’s departure but said generally speaking law firms are increasingly concerned about possible exposure under FARA, after Skadden Arps Slate Meagher & Flom early this year paid $4.6 million to settle with the DOJ its unregistered work for Ukrainian interests through Paul Manafort, Trump’s 2016 campaign manager.

Regarding Giuliani, some of his clients may have been “on the edge of what’s acceptable as business at a major law firm,” Adler said. “I certainly think that law firms are taking more time to vet potentially controversial clients because the backlash is greater today if they make a mistake.”