And Grenell’s public relations firm was paid to do work for a U.S. nonprofit funded almost entirely by the Hungarian government led by far-right Prime Minister Viktor Orban.

Grenell’s public relations consulting and foreign policy commentary, as well as his reputation as a vocal loyalist of Trump’s, are part of an unusual résumé for a leader of the U.S. intelligence community, a job Grenell assumed last week when Trump named him acting director of national intelligence. Individuals who have served in that position typically have been nonpartisan national security professionals whose experience has included leading intelligence agencies or service in the military.

Now that promotion is drawing fresh scrutiny to Grenell’s past, including his foreign affairs commentary and consulting work after he served as U.S. spokesman at the United Nations during the George W. Bush administration. His work for the Hungarian-funded nonprofit is the type of activity that, in other cases, has drawn the attention of Justice Department investigators tasked with enforcing the Foreign Agents Registration Act (FARA), according to two lawyers who specialize in that law. There is no indication that the Justice Department is looking into Grenell’s activities.

The law requires people who advocate in the United States on behalf of a foreign power to register and disclose their activities. Grenell did not register, records show. Craig Engle, who said he has been Grenell’s lawyer for several years, said he was not required to.

Grenell’s firm, Capitol Media Partners, worked for a range of clients, according to Grenell’s public financial disclosures, including law firms, advocacy organizations on anti-tax and gun rights issues, energy companies and celebrities including Kate del Castillo, an actress perhaps best known as the ex-girlfriend of Joaquin “El Chapo” Guzman, the drug kingpin. Grenell also represented people based in countries such as Iran, Kazakhstan, Somalia and China, according to an archived version of his personal website.

In the nearly two years before his nomination as ambassador, the disclosures show Grenell earned $668,362 from the firm, which he dissolved when he became ambassador.

In announcing his appointment as acting director of national intelligence, the White House emphasized Grenell’s experience working with the intelligence community as ambassador and while at the United Nations. Engle, who replied Friday to questions sent to the ambassador, said Grenell had never been paid to express a foreign policy opinion, understanding that would undermine his diplomatic integrity.

“He has always been a pro-west pro-democracy advocate. Anybody who knows him knows that,” Engle wrote in an email.

At his 2018 confirmation hearings, Grenell said that his opinion pieces about foreign policy and national security issues were part of his extensive attempts to defend democracy around the world and were unpaid work and his own views.

In a Washington Times op-ed published in March 2015, for example, Grenell accused Muhammadu Buhari – who was then the opposition candidate, and now is president – of wanting “Sharia law throughout Nigeria” and praised the incumbent president, Goodluck Jonathan, for his commitment to fighting the Islamist terrorist group, Boko Haram.

Jonathan had been criticized internationally in 2014 for a slow response to search for schoolgirls kidnapped by that group.

In 2016, Grenell repeatedly defended the Moldovan governing coalition, including in a Washington Examiner op-ed where he wrote that the allegations of corruption leveled against controversial political leader and businessman Vladimir Plahotniuc were exaggerated. Plahotniuc fled Moldova in mid-2019 after his party lost power.

In January, Secretary of State Mike Pompeo announced that Plahotniuc, whose whereabouts are not known, and his family were barred from entering the United States, citing the businessman’s alleged “corrupt actions” that “undermined the rule of law and severely compromised the independence of democratic institutions in Moldova.”

Grenell’s work with the Magyar Foundation, which was funded almost entirely by the Hungarian government, came in 2016 when his company did media outreach to help the group, according to the foundation’s tax filings and Engle. The foundation says its mission is to “promote Hungarian culture in North America and to engage Hungarian Americans in Hungarian-focused activities and events.”

The foundation, incorporated in Washington, D.C., paid Grenell’s firm $103,750 for public relations services in 2016, according to federal tax forms filed with the Internal Revenue Service.

The public financial disclosure form that Grenell filed when he was nominated to be an ambassador names his firm, which he founded, and 28 clients through the firm as sources of compensation. The foundation was not among the named clients. Engle said the payment was to Grenell’s firm, so it was included in the income attributed to Capitol Media Partners on the form.

In February 2016, the foundation put on an event in Washington to showcase research papers it funded. One of the papers presented at the event, written by a Pepperdine University scholar, concluded that under Orban – a leader who has often allied himself with the Kremlin’s positions, and who has cracked down on free speech and civil liberties – Hungary was becoming a “trendsetter in challenging the fundamentals of Western political correctness.”

Jo Anne Barnhart, a former lobbyist for Hungary before she became the foundation’s president and executive director, described the event to the Budapest Times in 2016. “The current relationship between Hungary and the US is strong and deep and we will work to make it even stronger,” she told the newspaper, adding that the foundation would work to engage “as many people as possible” in “thoughtful and intense discussions of public policy issues.” The government of Hungary supported the organization with a grant, she said.

Foundation tax filings for 2016 show that all of its $2.1 million in funding that year came from government donations, except for $165 in earnings from investments.

Barnhart did not respond to multiple interview requests left for her. Engle, Grenell’s attorney, was also a Magyar Foundation board member in 2016 and the organization’s general counsel. He confirmed that the Magyar Foundation was funded by the Hungarian government.

The Magyar Foundation is not listed in online records of FARA registrations. Engle said the organization was not required to register because “Hungary’s FARA work was segregated to a lobbyist under a different contract.”

Grenell also did not register under FARA. Engle said it was not necessary for Grenell to register “because of the nonprofit nature of the work of the foundation.” He said Grenell did media outreach for the foundation’s programs, including “academic programs, some fine arts programs and cultural and religious programs.”

A White House official, who said he was permitted to speak only on background, said Grenell had not registered under FARA because “he has never been employed by a foreign country,” noting that the Magyar Foundation was “operated by U.S. citizens with no foreign direction or control over how its moneys were spent.”

The Quincy Institute, a foreign policy think tank, published an online story about Grenell’s work for the Magyar Foundation on Monday.

Matthew Sanderson, an attorney who specializes in FARA, said that U.S. entities and U.S. citizens can still be agents of foreign governments – that’s what the law is meant to shed light on. Situations in which foreign governments heavily subsidize U.S. organizations are triggers for further scrutiny from the Justice Department, he said. Sanderson said while there are exemptions in the law for certain activities – such as religious, academic and fine arts activities – they are narrow.

“The Department has historically been very interested in this type of arrangement, has in the past found that registration was necessary in these types of circumstances, and I would expect them to be very interested in inquiring further and investigating whether Magyar Foundation and Richard Grenell should have registered as part of this activity,” Sanderson said.

Joshua Rosenstein, another attorney who specializes in FARA, agreed. “If you have a domestic organization, particularly a domestic nonprofit, which receives funding from a foreign government, it is certainly possible that you would have a registration obligation – even if your client is incorporated in the U.S.,” Rosenstein said. “In very similar situations, the Department of Justice has required registration by consultants working on behalf of U.S. nonprofits which were funded in part by foreign governments, where the purpose of the efforts in the U.S. were to strengthen ties between the U.S. and the foreign government.”

After enforcing FARA loosely for years, the Justice Department has cracked down recently, including in several high-profile cases that emerged from the investigation by special counsel Robert Mueller into Russian interference in the 2016 U.S. presidential election. Paul Manafort, Trump’s ex-campaign chair, admitted to conspiring to hide his lobbying activity on behalf of the Ukrainian government and political parties. A jury acquitted Democratic lobbyist Gregory Craig of charges that he had lied to investigators about his work for Ukraine to avoid registering under FARA.

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Alongside his public relations work, Grenell commented extensively on foreign policy issues in publications including HuffPost, Fox News and the Washington Examiner. He wrote and spoke about countries central to American foreign policy concerns, such as Iran and Syria, but he also focused on countries whose politics less often draw attention in the United States.

After he was nominated to serve as ambassador, Grenell told the Senate he had written numerous opinion pieces on his own initiative and with the aim of “confronting threats to democracy.”

Engle said Grenell has never been paid to express foreign policy opinions. “He wants to be very clear on this: when he writes his words are from his own ideas,” Engle wrote in an email. A White House official said Grenell had “never received any form of compensation from a foreign government.”

Grenell’s opinions on foreign policy drew particular attention due to his experience as U.S. spokesman at the United Nations, a position that he held from 2001 to 2008 and that gave him credibility on international affairs.

During Nigeria’s 2015 presidential race, Nigerian media covered Grenell’s op-ed after it was published in the Washington Times just days before polls opened. An opinion piece in the Guardian, one of the country’s largest newspapers, dismissed Grenell’s argument, and its claim that Buhari was a religious fanatic, as a “last minute hatchet job” by “foreign media mercenaries.”

Engle said Grenell was not compensated for writing the op-ed. Asked if Grenell had been compensated directly or indirectly by Nigeria-based interests or their representatives, Engle said in an email that “the only thing that comes close to answering this question is that Ric gave regular global foreign policy advice to many US consultants. These consultants paid Ric for his advice because Ric was the longest serving US Spokesman at the UN in history. Ric would have no idea who their clients were.”

One of the U.S. consultants Grenell worked for was the late Republican strategist Arthur Finkelstein, according to Engle and to Grenell’s public financial disclosures. Finkelstein worked on behalf of candidates both in this country and abroad. “Arthur had dozens of clients at a time and only he knew who they were,” Engle said. He said Finkelstein paid Grenell “for general foreign policy advice and not for the creation of ads or political consulting.”

ProPublica reported on Grenell’s work for Finkelstein on Friday.

During the Nigerian race, U.S.-based political consultant Joe Trippi was advising Jonathan, the candidate who would have benefited from Grenell’s op-ed. Trippi said Grenell was not part of the team advising Jonathan.

Grenell weighed in several times a year later on Moldovan politics – a run of interest that drew detailed written questions from Sen. Ben Cardin, D-Md., at Grenell’s confirmation hearing.

Grenell stood up for the governing coalition in the August 2016 Washington Examiner op-ed after a whistleblower accused members of the country’s ruling coalition of being involved in a billion-dollar bank fraud scheme. In a separate Fox News piece, Grenell argued that the whistleblower was a Russian operative.

He also appeared via Skype on Moldovan television, arguing against a resolution then in U.S. Congress that called for a deeper investigation into the whistleblower’s allegations against leaders in the coalition government and Plahotniuc by name. The resolution never went up for a vote.

Cardin in his questions specifically asked Grenell if he had been compensated for opining on Moldovan politics. Grenell said he had not.

“I believe strongly in confronting threats to democracy, and all of those views were my own opinion,” Grenell said in his written replies, emphasizing that many of his writings over the years aimed to highlight Russian disinformation campaigns and “meddling around the world.”

In response to a Cardin question about whether he’d written about Moldova at the request of a foreign entity, Grenell said he had not: “My motivation in writing or speaking on any particular subject is because I think it is important.”

Elliot Berke, an attorney who on Monday said he had been engaged by Grenell, responded to follow-up questions about the nature of Grenell’s work for Finkelstein.

“Ambassador Grenell did not work for Arthur Finkelstein’s clients, nor was he aware of who they were,” Berke said. “He gave Mr. Finkelstein media and strategic advice, and made introductions to United Nations diplomats and officials. Ambassador Grenell has never worked for a foreign government or politician, paid or unpaid. Any suggestion to the contrary is misleading and uninformed.”

Grenell is keeping his job as ambassador to Germany and special envoy for negotiations between Kosovo and Serbia as he serves as acting intelligence director, a role he has indicated will be brief.

“The President will announce the Nominee (not me) sometime soon,” Grenell tweeted on Thursday.