On the Potential Viability of Foreign Agent Charges for Rudy Giuliani

Since the NYT revealed that SDNY is investigating Rudy Giuliani for what they call “lobbying” laws,

Mr. Lutsenko initially asked Mr. Giuliani to represent him, according to the former mayor, who said he declined because it would have posed a conflict with his work for the president. Instead, Mr. Giuliani said, he interviewed Mr. Lutsenko for hours, then had one of his employees — a “professional investigator who works for my company” — write memos detailing the Ukrainian prosecutors’ claims about Ms. Yovanovitch, Mr. Biden and others.

Mr. Giuliani said he provided those memos to Secretary of State Mike Pompeo this year and was told that the State Department passed the memos to the F.B.I. He did not say who told him.

Mr. Giuliani said he also gave the memos to the columnist, John Solomon, who worked at the time for The Hill newspaper and published articles and videos critical of Ms. Yovanovitch, the Bidens and other Trump targets. It was unclear to what degree Mr. Giuliani’s memos served as fodder for Mr. Solomon, who independently interviewed Mr. Lutsenko and other sources.

Mr. Solomon did not immediately respond to a request for comment.

The lobbying disclosure law contains an exemption for legal work, and Mr. Giuliani said his efforts to unearth information and push both for investigations in Ukraine and for news coverage of his findings originated with his defense of Mr. Trump in the special counsel’s investigation.

He acknowledged that his work morphed into a more general dragnet for dirt on Mr. Trump’s targets but said that it was difficult to separate those lines of inquiry from his original mission of discrediting the origins of the special counsel’s investigation.

Mr. Giuliani said Mr. Lutsenko never specifically asked him to try to force Ms. Yovanovitch’s recall, saying he concluded himself that Mr. Lutsenko probably wanted her fired because he had complained that she was stifling his investigations.

“He didn’t say to me, ‘I came here to get Yovanovitch fired.’ He came here because he said he had been trying to transmit this information to your government for the past year, and had been unable to do it,” Mr. Giuliani said of his meeting in New York with Mr. Lutsenko. “I transmitted the information to the right people.”

And since the WSJ reported that Pete Sessions — named as Congressman 1 in the Lev Parnas/Igor Fruman indictment — was cooperating with a grand jury subpoena targeting Rudy,

A grand jury has issued a subpoena related to Manhattan federal prosecutors’ investigation into Rudy Giuliani, seeking documents from former Rep. Pete Sessions about his dealings with President Trump’s personal lawyer and associates, according to people familiar with the matter.

The subpoena seeks documents related to Mr. Giuliani’s business dealings with Ukraine and his involvement in efforts to oust the U.S. ambassador in Kyiv, as well as any interactions between Mr. Sessions, Mr. Giuliani and four men who were indicted last week on campaign-finance and conspiracy accounts, the people said.

Mr. Sessions’ knowledge of Mr. Giuliani’s dealings is a primary focus of the subpoena, the people said.

There has been a closer review of whether it would be possible to indict the President’s personal lawyer under foreign agent laws, with broad consensus that what Rudy is doing is actually covered by FARA — and not just his work for Ukraine, but also (among other places) for Turkey.

But there have been a number of claims that, I think, have been too pat about how easy or hard this is going to be.

Greg Craig, Tony Podesta, Vin Weber, and Bijan Kian are not apt precedents

First, a number of people have looked at how SDNY considered — but did not charge — Greg Craig, Tony Podesta, and Vin Weber under FARA, suggesting the same considerations would hold true with Rudy. Others have looked at Greg Craig (who was prosecuted but acquitted in DC for FARA after SDNY decided not to charge it) and Bijan Kian (who was convicted but then had his conviction thrown out by Judge Anthony Trenga based on the legal theory DOJ used) to suggest these cases are too difficult to charge to get Rudy.

It is absolutely the case that when powerful men with skilled lawyers have been pursued under FARA in recent years, DOJ has succeeded not in trial, but instead has gotten either plea deals or failed at trial (and that may have been one of the facts behind Mueller’s decision to strike a plea deal with Paul Manafort). That is sound evidence that SDNY is no doubt aware of.

But several things distinguish Rudy.

Most notably, all of those earlier cases came before DOJ’s newfound commitment to prosecuting FARA, with Mike Flynn prosecutor Brandon Van Grack taking over where a woman named Heather Hunt had been in charge before. At a minimum, that means a process that originally took place with Craig, Podesta, Weber, and Kian under an assumption that FARA would be treated solely as a registration issue may now be taking place under an assumption that violations of FARA — presumably to include both a failure to register and (what most charges have been so far) false statements under registration — can be prosecuted. That assumption would dramatically change the attention with which DOJ would document their communications, so prosecutors would not now be stuck going to trial (as Craig’s prosecutors were) without having DOJ’s documentation of a key meeting.

Notably, the same thing that triggered the FARA prosecution of Mike Flynn — concerns raised by Congress — happened last year when seven Democratic Senators wrote National Security Division head John Demers asking for a review. So there may well be documentation of Rudy’s claims about whether he does or does not need to register that SDNY is building a prosecution around.

Plus, one thing clearly distinguishes Rudy from all these other men. Rudy is not taking this investigation seriously, and does not have a lawyer reviewing his exposure. From reports, he may not have the ready cash to pay the likes of Rob Kelner (Flynn’s original, very competent, lawyer) or Robert Trout (Kian’s excellent lawyer). So he may be doing things now (not least, running his mouth on TV and making public statements about who he works for and how it gets paid) that put him at greater exposure.

Rudy G’s efforts to implicate State and DOJ (and the President) in his work

That said, another thing distinguishes Rudy from these past cases. Since the whistleblower complaint got made public, he has spent most of his time insisting that everything he did, he did with the awareness and involvement of — at least — the State Department. And in Trump’s July 25 call to Volodymyr Zelensky, he invoked Bill Barr’s name right alongside his nominal defense attorney.

Both foreign agent statutes (FARA — the one being discussed for Rudy, and 18 USC 951 — another one, with more flexibility, that Kian was charged under) require registration with the Attorney General. And while telling foreigners you’re negotiating with that the Attorney General will be by soon to pick up the disinformation demanded does not fulfill the requirements for registry (in part, the point of registering is to provide a paper trail so the public can track who is paying for what), it does change things that Rudy is suggesting that his work has the imprimatur of official policy to it.

That said, the assumption that implicating powerful government figures will keep you safe is a dangerous proposition. If the easiest way to end the Ukraine inquiry is to blame Rudy for it all (and if that’s still possible after several weeks of damning testimony), that may well come to pass.

And if Bill Barr needs to greenlight a FARA prosecution of Rudy as a way to minimize the damage to the Administration, and to himself, he may well do that (yet another reason why he should have recused long ago).

That’s all the more true given that most of Trump’s aides seem to recognize how damaging Rudy is for Trump’s exposure. If Trump won’t separate himself from Rudy, his lackeys might one day decide, then separate Rudy from Trump by prosecuting him, the same way they separated Michael Cohen from Trump.

That said, with Trump, loyalty is always transactional. And if he believes Rudy has dirt that can bring him down — and given the likelihood some of what Rudy is doing is the continuation of what Paul Manafort had been doing since August 2, 2016, that may be true — then Trump will defend Rudy’s work even if it means claiming everything he did operated under Article II authority.

The additional factor: ConFraudUs

The discussions about Rudy’s exposure under FARA, however, seem not to have considered another factor: that Lev Parnas and Igor Fruman have already been charged with conspiracy in conjunction with actions Rudy had a key role in. The Ukrainian grifter indictment charges them with two counts of Conspiracy to Defraud the US for hiding what money was behind their influence campaign on Ukraine (count 1) and Nevada marijuana (count 4), as well as False Statements to the FEC (count 2) and falsification of records (count 3) tied to the Ukraine influence operation. Counts 1-3 all pertain to the Ukrainian grifters laundering of campaign funds through Global Energy Producers, a front that (SDNY alleges) they falsely claimed was “a real business enterprise funded with substantial bona fide capital investment,” the major purpose of which “is energy trading, not political activity.” Those funds went, among other places, to the Trump related Super PAC America First Action and to Congressman Sessions.

Rudy has equivocated about his relationship to the Ukrainian grifters (and claims it goes through Fraud Guarantee, not GEP). But John Dowd, writing as the grifters’ lawyer, already stated for the record that he does have ties and those ties relate to his representation of the President. That is, the grifters are working for him, even while he works for them.

That’s important because Sessions’ statements have denied any official action in response to meetings with the grifters, but he also had meetings with Rudy in the time period, official action in response to which he has not denied. In addition, Rudy (whom Sessions says he has been friends with for three decades) also headlined a fundraiser for Sessions. And on top of the straw donations the grifters gave Sessions directly, America First Action gave Sessions far more to him, $3 million, the indictment notes twice.

In other words, while Sessions has denied doing anything in response to the grifters’ meetings, he has not denied doing anything in response to Rudy’s communications with him. If he sent his letter calling for the ouster of Marie Yovanovitch in response to a request from Rudy — whose finances are inextricably tied to the grifters — then it may be fairly easy to add him to the conspiracy the (successful) object of which was to get Yovanovitch fired. The propaganda Rudy sent (as laid out by NYT, and which the State IG already sent to the FBI earlier this year) would then simply be part of the conspiracy.

A few more points. There’s a passage of the indictment included to substantiate the allegation that the grifters were affirmatively trying to hide their purpose.

Indeed, when media reports about the GEP contributions first surfaced, an individual working with PARNAS remarked, “[t]his is what happens when you become visible … the buzzards descend,” to which PARNAS responded, “[t]hat’s why we need to stay under the radar…”

The indictment doesn’t disclose a number of details about this communication: who the interlocutor is, how it was collected, and whether it involved a mere warrant (for stored communications such as email or texts) or a wiretap. But particularly given the seeming overlap between these activities and those of people we know were surveilled during the period in question, it’s a pregnant inclusion in the indictment. It suggests the Feds may already be privy to far more about this scheme and the reasons the grifters might want it suppressed. Add that to the fact that, as WSJ reported, the Feds already have Rudy’s bank records, which will show whether he really worked for Fraud Guarantee or whether that, like GEP, is just a front.

Cui bono

Finally, consider this. The indictment says that the grifters were pushing to oust Yovanovitch to benefit  particular unnamed Ukrainians’ interests.

[T]hese contributions were made for the purpose of gaining influence with politicians so as to advance their own personal financial interests and the political interests of Ukrainian government officials, including at least one Ukrainian government official with whom they were working.


At and around the time PARNAS and FRUMAN committed to raising those funds for [Sessions], PARNAS met with [SESSIONS] and sought [his] assistance in causing the U.S. Government to remove or recall [Yovanovitch]. PARNAS’s efforts to remove the Ambassador were conducted, at least in part, at the request of one or more Ukrainian government officials.

According to NBC, the Ukrainian in question was Yurii Lutsenko. But Lutsenko has since been ousted, and he has reneged on statements elicited by Rudy implicating the Bidens. More importantly, one of the promises Zelensky made in his July 25 call to Trump was to put in his own prosecutor who would pursue the two investigations — to trump up a claim Ukraine was behind the election tampering in 2016, and to invent evidence against Hunter Biden — that Trump wanted.

The President: Good because I heard you had a prosecutor who was very good and he was shut down and that’s really unfair. A lot of people are talking about that, the way they shut your very good prosecutor down and you had some very bad people involved. Mr. Giuliani is a highly respected man. He was the mayor bf New York Ci:ty, a great mayor, and I would like him to call you. I will ask him to call you along with the Attorney General. Rudy very much knows what’s happening and he is a very capable guy. If you could speak to him that would be great. The former ambassador from the United States, the woman, was bad news and the people she was dealing with in the Ukraine were bad news so I just want to let you know that. The oteer thing, There’s a lot of talk about Biden’s son. that Biden stopped the prosecution and a lot of people want to find out about that so whatever you can do with the Attorney General would be great. Biden went around bragging that he stopped the prosecution so if you can look into it … It sounds horrible to me.

President Zelenskyy: I wanted to tell ·you about the prosecutor. First of all I understand arid I’m knowledgeable about the situation. Since we have won the absolute majority in our Parliament; the next prosecutor general will be 100% my person, my candidate, who will be approved, by the parliament and will start as a new prosecutor in September. He or she will look. into the situation, specifically to the company that you mentioned in this issue.

Which is what led to Lutsenko’s ouster.

Moreover, the prosecutor Biden shut down was not Lutsenko, but Viktor Shokin, who has written affidavits which then got fed to John Solomon on behalf of Dmitry Firtash, who is trying hard to avoid extradition (on bribery charges) to the US.

That — plus the financial and legal ties between Firtash and the grifters — suggests there may be other Ukrainians on whose behalf the grifters were working to get Yovanovitch withdrawn. Firtash is certainly one. A corrupt prosecutor with ties to Russian intelligence, Kostiantyn Kulyk, who had worked for all these guys — and who is behind a dossier on accusing Hunter Biden of corruption — may be another. That is, Yovanovitch may have been the impediment not to inventing dirt on the Bidens, which is a fairly easy ask, but instead on creating the pre-conditions for people like Firtash to go free (which would also explain the natural gas angle).

All of which is to say that it would be a fairly trivial matter to establish the evidence to charge Rudy in ConFraudUs along with the Ukrainian grifters, as SDNY already has a lot of the evidence it would need.

Yes, Rudy Giuliani is, by all appearances, in blatant violation of FARA. Yes, he may get away with that, in part because DOJ hasn’t yet figured out hard to charge it consistently (though knows what not to do given recent history), and in part because he has made sure to implicate Trump and his cabinet officials.

But there’s a larger question about whether those same financial ties expose Rudy for much uglier conspiracy charges.

40 replies
  1. Mister Sterling says:

    I have wondered about Rudy not retaining a defense counsel. Could he have cash overseas? Could he not have the cash? Is he a drug addict or compulsive gambler? Where’s all the money he made giving paid speeches about counter-terrorism? Where’s the money, Rudy?

    What’s the over/under Rudy is indicted before Halloween?

      • earlofhuntingdon says:

        Anything not declared to the NY state court in connection with the divorce proceedings would cause Rudy no end of career-ending trouble.

        He could not possibly argue he was unaware of any requirement. Apart from being a lawyer, and former mayor and USA, he’s been through this exact proceeding in this jurisdiction before.

        His divorcing spouse would be likely to strenuously cry foul were Rudy found to have secreted funds offshore, in which he had an interest at the time of the divorce. If he had funds, but claimed to have no legal or beneficial interest in them, he would be hard-pressed to explain how he later acquired one.

        I would guess that Rudy, like Trump, is running on empty.

        • rip says:

          Career-ending only applies to normal people. Not those that thrive in a cesspool of under-the-table and behind-the-shed transactions.

          Both of the gents you suggest are “running on empty” are sucking fumes from each other’s behinds just to barely keep alive. Through in a Big Barr Butt and a few others and the methane might fuel a trumpster bus to the pen.

  2. TerrySalad says:

    I think Rudy drinks, which is a shame and he probably needs help. And, I think he’s going to prison.

    • General Sternwood says:

      More importantly for Barr, as a criminal defendant Giuliani will have several new layers of protection against the impeachment inquiry.

  3. Frank says:

    Rudy is going through a terrible divorce, spent a ton on his last marriage and its trappings as America’s Mayor, and his assorted businesses seemed to have dried up in some way. There was some rumor recently he worked free for Trump to create a record in the New York courts that he was destitute with no income, to affect his alimony determination

    • earlofhuntingdon says:

      The arrangement you suggest Rudy tried to claim would have been fraudulent. Such high-profile representation is nearly always compensated, in kind if not in cash. And manipulating oneself into poverty – volunteering to work for free so as to appear to have no income – when one has the ready means to be flush with cash, is another kind of fraud.

      But that sort of high-stakes gamesmanship seems very Rudy, as it is very Trump.

    • Frank Probst says:

      Hi there! Could you please do me a huge favor and add some sort of suffix to your name, like “Frank D” or any other letter but “P”? I have a reputation here for asking questions that are totally clueless, and for your sake, I don’t want the two of us to get lumped together. Thanks!

    • Tracy Lynn says:

      Good Lord! Are you suggesting all of Rudy’s recent crazy is because his soon-to-be former wife is trying to take him for everything he’s worth?

      • posaune says:

        I keep thinking that Judith Nathan should expedite the divorce settlement before Rudy’s spent all his $ on criminal defense attorneys. Seems more likely to me than Judith finding some hidden lode. (unless someone else is hiding it for him). But what do I know about divorce? Absolutely nothing.

      • earlofhuntingdon says:

        No. Rudy is crazy, and desperate for fame and fortune. That’s what he does at work.

        What he does at home is separate, but he is no less of a shit. He is a serial adulterer, who divorces one spouse only after he’s engaged to his next one. His behavior during divorce proceedings is nasty.

        • Eureka says:

          Yes, Rudy’s reputation for assignations so precedes him that some even suspect that that well-publicized dalliance in New Hampshire was a smokescreen for nefarious activity there. Something about that small hospital with millions of medical records, Rudy’s “cybersecurity” expertise, and his intra/ international friends.

          Anyway, it all does make me wonder what they are cooking up in NH, with Pence’s cancelled big announcement (Rayne’s ~ “Mysterious Veep Backflip” post); Lewandowski’s run. It’s like a domestic base of GOP operations or something.

          We might need to watch where this ball is bouncing, too.

          Adding: documentation here, written in 2018 (so while lacking benefit of hindsight, writer is one of a handful who has been on the Giuliani Ukraine beat in ~ real time), re spring 2018+, with all of the requisite geopolitical intrigue:

          L’Affaire Hampshire: Did Rudy Giuliani use a cheating scandal as cover for an illicit medical data operation?

          Recall also that Zuck was looking for medical records (here’s one example):

          Facebook Building 8 explored data sharing agreement with hospitals
          Apr 05, 2018 · Facebook was in talks with top hospitals and other medical groups as recently as last month about a proposal to share data about the social networks of their most vulnerable patients.

    • Bunnyvelour says:

      I wonder if the “working for free” arrangement isn’t similar to Manafort’s when he was trump’s campaign manager. More like a complicated kickback scheme.

  4. PhoneInducedPinkEye says:

    I take it you got some feedback then on whether Rudy just telling Barr isn’t enough to count as registration for FARA?

  5. Inspector Clouseau says:

    With Rudy going through a divorce now I was hoping someone might help answer this who understands the flow of the courts. Should any payments/income/assets come up that weren’t disclosed in his financial asset forms during his divorcee proceedings, when does that lawyer/court get to take a shot at him? Does the court delay his divorcee proceedings while this SNDY case proceeds? Can any shield of executive or attorney client privilege be applied to making those disclosures to his wife’s attorney?

  6. Frank Probst says:

    This part is confusing me:

    “Notably, the same thing that triggered the FARA prosecution of Mike Flynn — concerns raised by Congress — happened last year when seven Democratic Senators wrote National Security Division head John Demers asking for a review.”

    Is this a different Mike Flynn than the one we’ve been talking about? His prosecution wasn’t last year, was it? I have trouble keeping up with all of this, and we’ve added a whole new cast of characters in the last two weeks. I can’t keep up with this like you can, but can you clarify here? The Mike Flynn reference has me totally lost.

  7. MattyG says:

    Rudi: “I did it on instructions of the President.”

    How far would spilling the beans take him? If he doesn’t spill the beans it probably means a very powerful non-US party still fully enjoying DTs “accommodating” foreign policy has persuasive means of changing Rudi’s mind about doing anything like that.

  8. Yastreblyansky says:

    Speaking of Giuliani providing fodder to John Solomon, it seems possible he was doing that in the fall of 2016, when Solomon was reporting rumors about Hillary Clinton and the email investigation for a now defunct website called Circa , e.g. https://dailycaller.com/2016/09/02/report-fbi-found-ample-evidence-that-clinton-violated-federal-records-act/ and more relevantly this https://townhall.com/tipsheet/mattvespa/2016/11/03/perjury-clinton-also-swore-she-turned-over-all-state-department-emails-her-lawyer-seemed-uncertain-n2240992 — things that could have come from the FBI New York field office.

    Solomon also promoted Giuliani’s post-9/11 career in 2007 http://www.washingtonpost.com/wp-dyn/content/article/2007/05/12/AR2007051201270_pf.html so it could be a very long relationship

    Is this interesting? If it is, it’s too in-the-weeds for me to write up, so I’d be glad if somebody else would.

  9. Dead Last says:

    Is there a connection between what Michael Flynn was doing in Turkey and what Trump has done to the Kurds?

    It seems to me that the big issues is natural gas and heating for Europe. The USA has too much natural gas resulting from fracking to sell into the domestic market. The Three Amigos were interested in selling LNG to Ukraine. There has long been talk of building a Turkish pipeline from Russia that would cut out the Ukrainians and force Germany et al to buy LNG through Turkey (and make USA LNG price competitive).

    Given Rudy’s penchant for providing “anti-terrorist consulting” and “legal services”, it is difficult to imagine him not involved in Turkey. Given the players, it is highly possible that Rudy picked up Flynn’s baton.


  10. Matthew Harris says:

    My own guess is that rather than being a FARA prosecution, which is pretty esoteric and hard to prove, it will be something very boring, yet very practical. With all of the money moving around in odd ways, probably some of it wasn’t accounted for, for tax purposes, and possibly there was some “structuring” involved.

    All of which could be easy to deal with for a young, healthy man who could retain a lawyer, and who could keep his mouth shut. Financial crimes that could end with a 6 month stay in a minimum security prison are something a lot of people could deal with. But Rudy is 75, and probably doesn’t want to go to prison. And he doesn’t seem to be helping his defense any.

    • emptywheel says:

      Yup. Wire fraud is missing from the existing indictment but it’s not hard to see it being added.

      • Matthew Harris says:

        I guess to me, it comes down to “What are the chances that a 75 year old man who seems to have a drinking problem, and who is often not very careful with what he says in public, has been prudent enough with his financial affairs with large amounts of foreign money, that a team of FBI white collar crime experts aren’t going to be able to find a mistake?”

        It is somewhat ironic and a moral quandary in cases like these. Dennis Hastert used a position of power to sexually molest a young man, and ended up getting caught for…how he withdrew money from a bank. Something that he actually could have done legally, easily enough. From a moral point of view, maybe it doesn’t make sense that people get punished for “procedural crimes”, but I don’t have a lot of extra sympathy to spare in a case like this. Especially for someone like Giuliani, who is wealthy, knowledgeable and connected enough that if he can’t figure out how to keep his finances legal, he has no one to blame but himself.

  11. Yohei72 says:

    Speaking as someone who’s lived in New York City for 23 years, which included the majority of Giuliani’s time as mayor – seeing him end up behind bars would be almost as gratifying as seeing that happen to Trump. I’ve been hearing a lot of “Rudy used to be so great, what happened to him?” nonsense recently. I’ve been at pains to explain to people that he was always this guy – he’s just more naked about it now.

    • john b 1955 says:

      As a New Yorker I have to agree. Rudy did a real hatchet job on David Dinkins in the 1993 campaign for mayor. The guy we see today is the same guy we saw back then only now he doesn’t seem to try and cover up his squalid behavior. As I recall, back in 2001 the city was pretty much over its infatuation with Mayor Giuliani (see: Abner Louima) then came 911 and things were different. Since that time it has been a long, almost imperceptible, downhill run for America’s Mayor, but it has always been downhill. I reckon we stay tuned to see where he bottoms-out.

      • P J Evans says:

        From way over here in CA, it’s hard to believe that anyone even thought he was “America’s Mayor”.

  12. Eureka says:

    I enjoyed the LOLs from your quote of NYT; Thanks for spelling it out, Rudy– at least there’s something on which we can all agree:

    He acknowledged that his work morphed into a more general dragnet for dirt on Mr. Trump’s targets but said that it was difficult to separate those lines of inquiry from his original mission of discrediting the origins of the special counsel’s investigation.
    (emphasis added here)

    A topical (and amusing) throw-back quote from Dec 2018 (context: he was calling Cohen an incompetent international fixer to explain contradictory Trump Tower Moscow statements by Trump):

    “Cohen didn’t even know where to send the got damn emails,” Giuliani said, referencing a pitch Cohen — then Trump’s personal attorney and fixer — sent to a representative for Vladimir Putin’s press secretary in early 2016. “That tells me he doesn’t know s–t about Russia.”

    Asked what was wrong about Cohen’s pitch, Giuliani said it was sent to a “general email address.” He didn’t specify where Cohen should have sent it instead.

    “I do a lot of work in Poland and Hungary, and if I needed to send something I would know where to send it,” Giuliani said.

    Rudy Giuliani blames Michael Cohen for Trump’s inconsistent Russia claims, says fixer did ‘s–t’ job on Moscow tower

  13. Mulder says:

    I don’t pretend to be able to make good sense of the energy angle to all of the Ukraine/Rudy/Perry/Vladdie etc. entanglements but seems to me that this is ultimately about Russia being able to leverage it’s gas supplies to the max.

    Vladdie gets the EU and we get Ukraine? I’ve been reading some technical energy blogs, articles and twitter feeds. Way over my head but I came across this.

    This I can understand. https://foreignpolicy.com/2019/10/07/gazproms-nord-stream-2-will-help-putin-cut-off-natural-gas-supplies-to-europe/

    And I can’t get this to render on the web page but the description is…”As a long-term gas transit contract between Ukraine’s Naftogaz and Russia’s Gazprom expires at the end of 2019, countries and companies have expressed concerns that Russia will stop deliveries, leaving millions of European and Turkish consumers out in the cold.

    This infographic by ICIS reporters examines supply options and storage levels across key countries affected and shows the countries which are most at risk of gas supply shortages this winter…”


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