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(CNN) —  

When a well-known Ukrainian politician and leading presidential candidate visited Washington, DC, late last year, Rudy Giuliani was ready and willing to meet.

On December 5, 2018, Giuliani spent 45 minutes meeting with former Ukrainian Prime Minister Yulia Tymoshenko, who was looking to make connections to people close to President Donald Trump.

The encounter, which took place at the Willard Hotel, just a five-minute walk from the White House, indicates Ukrainian officials saw Giuliani, Trump’s personal attorney, as a valuable link to the American President. It also raises questions as to whether Giuliani’s shadow diplomacy efforts over the next year were also an effort to drum up business for his consulting group.

Tymoshenko was hoping Giuliani could broker a meeting with Trump and perhaps even arrange a picture with him, neither of which happened. But a person familiar with their interactions said Giuliani also wanted something in return: business.

Giuliani disputes the purpose of the meeting, which was included in disclosure forms filed by Tymoshenko’s lobbyists, telling CNN he never offered to work for Tymoshenko or enter into any sort of business relationship with her.

“She wanted to meet with me because she wanted me to support her for president,” Giuliani told CNN. “She probably wanted me to tell the President that she was the best one to win.”

To Giuliani it was clear from the meeting that Tymoshenko wanted him to send a message to the President: that “she’d be the most loyal to Trump.”

Tymoshenko did not respond to CNN’s requests for comment.

At the time of the meeting, Giuliani was just beginning his effort to gather information from Ukrainian sources about Trump’s political enemies, work that has now become a focus of the impeachment inquiry in the House of Representatives.

His meeting with Tymoshenko highlights how Giuliani was presenting himself as a key point of contact for foreign officials looking for access to the President. One lobbyist told CNN that Giuliani was viewed in the private influence industry as a person who could compete for foreign business – especially because of how he touted his access to Trump.

In this way, the President’s personal attorney appears to be filling the role once occupied by former Trump campaign chairman Paul Manafort, who was a key consultant in Ukrainian politics before he was convicted of tax and bank fraud and admitted to illegal foreign lobbying. There’s no indication, however, that Giuliani’s meeting with Tymoshenko crossed the line of the foreign lobbying law.

Yet his efforts related to Ukraine over the past two years have caught the attention of Democratic senators, who in late September wrote to the Justice Department’s foreign lobbying enforcement unit with questions about whether Giuliani has complied with the law.

According to experts on the Foreign Agents Registration Act, the law that compels people lobbying for foreign entities to disclose that work, Tymoshenko’s meeting with Giuliani may not have needed to be reported under the law.

But according to these experts, there are several reasons why the lobbying firm hired by Tymoshenko may have thought otherwise: due to his frequency appearing on TV news networks, and because of his role as a former official, as well as his proximity to the President.

On the disclosure forms, registered foreign agents are “supposed to describe all contacts with U.S. persons, regardless of whether they hold government office,” said Matthew Sanderson, a Washington lawyer who focuses on foreign lobbying and political law at the law firm Caplin & Drysdale.

A valuable commodity

During her December trip, Tymoshenko traveled around Washington for five days, according to foreign lobbying disclosures. In all, the former prime minister took at least nine separate meetings.

 Former Ukrainian Prime Minister Yulia Tymoshenko addresses the crowd in Independence Square after being freed from prison on February 22, 2014 in Kiev, Ukraine.
Jeff J Mitchell/Getty Images
Former Ukrainian Prime Minister Yulia Tymoshenko addresses the crowd in Independence Square after being freed from prison on February 22, 2014 in Kiev, Ukraine.

Her interlocuters ranged from government officials to political scholars. She sat in on roundtable discussions at think tanks, visited members of Congress including Republican Sen. Tom Cotton of Arkansas and Democratic Rep. Adam Schiff of California, and interacted with State Department officials. Though Tymoshenko did not visit with White House staff, according to the filings, then-Trump chief of staff John Kelly and an assistant for Ivanka Trump had discussed her trip to Washington several times with her handlers.

Some of her visits included people now central to questions about the President’s intentions in Ukraine, including now-former State Department Special Representative Kurt Volker. Her lobbyists were also in touch with Vice President Mike Pence’s national security adviser Keith Kellogg.

For nearly all of her meetings, Tymoshenko traveled with a delegation. But for her meeting with Giuliani, he came to her at the Willard, where she was staying.

The meeting she had with Giuliani also sticks out in the way it’s described in the disclosure forms filed by her lobbying firm, the Livingston Group. It’s the only one described as an “occasion to introduce” Tymoshenko to Giuliani, giving it an air of informality.

Also at the meeting, according to the disclosure forms, were former Republican Rep. Bob McEwen of Ohio, a registered lobbyist, and former Reagan administration Attorney General Ed Meese.

But it’s unclear whether the pair attended with Giuliani.

“I have no knowledge of any such meeting,” Meese told CNN through a spokesperson.

McEwen did not respond to requests for comment.

Serhiy Leshchenko, a former Ukrainian lawmaker and journalist, told CNN that Tymoshenko was “actively looking for a contact on Trump’s team” and the other Ukrainian presidential candidates were doing the same thing.

Rudy Giuliania and Yulia Tymoshenko met in December 2018
Getty/AP
Rudy Giuliania and Yulia Tymoshenko met in December 2018

“I believe everybody was looking to have contact with Trump and Giuliani,” Leshchenko said

An additional lobbyist who has represented Ukrainian clients told CNN that he separately met with Tymoshenko in February 2018 and that Tymoshenko wanted to make inroads with the Trump administration and specifically wanted a photo with Trump.

The lobbyist said an endorsement from Trump would have been highly valuable in the Ukrainian presidential race: “In Ukraine, a picture with the president is a valuable commodity.”

Tymoshenko got a photo with Giuliani instead.

Looking for foreign work

Giuliani has never registered as a foreign lobbyist. But in the years since leaving New York City Hall in 2002, he has had plenty of foreign clients – including in Ukraine. Through his firm Giuliani Partners, he has performed security consulting in foreign countries. He told The Washington Post in 2018 that he had such clients in Brazil and Colombia, “among other countries.”

Some in Washington’s foreign lobbying community have noticed Giuliani’s efforts to drum up more business with foreign clients during 2018.

One lobbyist who has advised Ukrainians told CNN that it “makes complete sense” that Giuliani might have been interested in working for Tymoshenko, who at the time was considered a leading candidate in Ukraine’s presidential election. The lobbyist added that Giuliani’s firm did not have a wide range of political clients.

In 2018, Giuliani was facing several challenges. His third wife, Judith, had filed for divorce in April, which he is still contesting in court. A month later, Giuliani was dropped from his position at Greenberg Traurig, a major law firm. As the special counsel investigation into Russian election interference continued, Trump had added Giuliani to his legal team, work that Giuliani continues to say he does pro bono.

Divorce hearing records obtained by CNN also show Giuliani’s lawyer Faith Miller describing her client’s financial strain and the need to work “three jobs” to maintain his standard of income.

“He’s constantly traveling, constantly running all over the world literally making speeches through the Washington Speaker’s Bureau, meeting clients for the Giuliani entities either to fulfill a contract or in the hopes of garnering new business,” said Miller.

Ukraine has been a source of some of Giuliani’s work in recent years. In early 2017, Pavel Fuchs, a Russian-Ukrainian businessman from an eastern Ukraine city called Kharkov, hired Giuliani. Fuchs told The New York Times in June he considers that Giuliani was a “lobbyist for [Kharkov] and Ukraine.” Giuliani was not a registered lobbyist for Kharkov, and there’s no clear indication his work for the city would need to be registered with the Department of Justice. The law does not require the disclosure of lobbying done in foreign countries; it applies only to lobbying and public relations work done in the United States.

Giuliani traveled in November to Ukraine and met with the mayor of Kharkov, Gennady Kernes. Kernes was a member of the pro-Russian Party of Regions and a supporter of former Ukrainian President Viktor Yanukovych, who had close ties to Manafort.

During his trip, Giuliani, a prosecutor before he became New York’s mayor in the 1990s, delivered a speech about traffic safety and the rule of law. Kharkov has released a photograph of Giuliani arriving, stepping out of what appears to be a private jet.

Giuliani told CNN he no longer works for Kernes or the city of Kharkov. He is more circumspect about his efforts last year to find more clients in Ukraine, and was insistent Thursday about the nature of his December meeting with Tymoshenko.

“Never tried to get business from Miss T ever,” Giuliani told CNN via text message.

CNN’s Pamela Brown, Tim Lister and Audrey Ash contributed to this report.