Giuliani Should Comply with Federal Ethics Laws Due to Assigned Role in U.S.-Ukraine Diplomacy


WASHINGTON – Rudy Giuliani has been tasked with conducting U.S. foreign policy while retaining unknown private clients, and should be subject to the conflict of interest and other ethics laws that apply to federal employees. A new letter sent by Campaign Legal Center (CLC) to the State Department’s Inspector General requests an investigation into Giuliani and his potential violations of ethics laws.

According to the letter, Giuliani’s assigned role and diplomatic responsibilities rendered him an employee for purposes of federal ethics laws. President Donald Trump identified Giuliani as an official envoy to Ukrainian President Volodymyr Zelensky. Senior State Department officials understood that the president had given Giuliani formal responsibilities on U.S.-Ukraine relations, and deferred to him on substantial diplomatic matters. And Giuliani himself stated publicly that he acted with the support of the president and State Department.

“Giuliani has been afforded the privilege and power of federal public service, but he has not been subject to the vital oversight and accountability provided by federal ethics laws,” said Delaney Marsco, ethics counsel at CLC. “Rudy Giuliani has asserted that his Ukraine work was done solely as a defense attorney for his client, Donald Trump, but the facts – and Giuliani’s own statements – show otherwise.”

“President Trump assigned Giuliani a substantial foreign policy role, but at the same time, Giuliani continued to represent private clients, many of whom are not publicly known,” said Brendan Fischer, director, federal reform at CLC. “Giuliani’s prominent role on U.S-Ukraine policy issues means that he cannot sidestep the ethics obligations that require transparency behind the wealthy foreign or domestic interests that are paying him. We expect the agency Inspector General to take this matter seriously.”

Giuliani was assigned a central role in pushing Ukraine to publicly commit to investigations into Joe Biden and Burisma, a Ukrainian firm that employed Biden’s son Hunter – and into matters pertaining to the Democratic National Committee (DNC) – which were understood to be necessary preconditions for the release of U.S. taxpayer-funded security aid to Ukraine and for President Zelensky receiving the in-person White House meeting that he sought. These facts are central to this week’s public impeachment hearings.