In September 2024 former Moldovan prime minister and presidential hopeful Vasile Tarlev was the subject of a Foreign Agents Registration Act (FARA) filing with the US Department of Justice. Under the filing, the PR / lobbying firm Qorvis undertook to burnish the image of Mr. Tarlev and to set up high level meetings for him during his planned December 2024 trip to Washington DC.

The trip never took place, but Qorvis was paid $45,000 of the original $85,000 contract. Moldova Matters published a multi-part investigation into this story over the course of the last year. The story has two components, what was Mr. Tarlev hoping to accomplish in Washington DC? and who paid Qorvis on his behalf?

New FARA filings finally provide us with some answers to these questions. But before we jump in, if you haven’t read parts 1 & 2 of this story, start there -

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Putting the Pieces Together

Since October 2024 Moldova Matters has been investigating efforts by Moldovan politicians linked with fugitive and sanctioned oligarch Ilan Shor to contract American PR and lobbying firms. We reported on how Stanislav Pavlovschi organized a mass astroturfed campaign in the US, EU (and in Chisinau) to undermine Moldova’s European aspirations, and how Shor found replacement agents of influence to send to Washington after Mr. Tarlev failed.

In our last update on the Tarlev investigation we tracked how Qorvis’ FARA filings showed that the company’s employees had reached out to multiple members of congress, international institutions and at least one press outlet to “Gauge Interest in Meeting with Vasile Tarlev.” At the same time we found that at least one contact with a think tank was not reported - the implication not necessarily being nefarious, but an indication that the filing was demonstrably incomplete. Something that could have serious consequences under US Federal Law if not corrected.

At the same time, there was a huge ambiguity in the $45,000 payment. The contract to support Mr. Tarlev was signed by Sam Alaverdov, the director of the “American Charity Fund for Helping Children of Ukraine and Moldova Inc” (ACFHCUM1). This NGO, of somewhat ambiguous tax status, agreed to the original $85,000 contract in support of Mr. Tarlev. At the same time, Qorvis reported receiving the $45,000 retainer fee directly from Mr. Tarlev himself.

Qorvis declined to comment on the record for the previous story, or for this one, but has been aware of the reporting that Moldova Matters has conducted. Shortly after our last article they filed an amendment to clean up some of these ambiguities… kinda.

Amendment #1 - June 18, 2025

This first amendment set out to correct both ambiguities previously reported by Moldova Matters. They explained the amendment as follows:

Qorvis then updated the list of activities conducted to include 2 more Think Tanks not previously reported in their filings. Oddly, they did not include the Atlantic Council which we reported on last time as being omitted.

These contacts don’t much change our understanding of their work for Mr. Tarlev. They were sent the same day as the majority of the previously reported emails and show no followup - likely they went unanswered.

As to payments, the FARA amendment now clearly stated that ACFHCUM paid, as the organization had agreed to under their contract.

Ok, so it’s now clear. In the open question that we discussed in the last article between whether ACFHCUM or Tarlev paid, now we know… Not quite.

Amendment #2 - July 2nd, 2025

Qorvis then filed a second amendment that added to and corrected the first. The description on this amendment is as follows:

They added one more meeting request with the Atlantic Council, which Moldova Matters had previously reported:

And they provided a final update on who paid them:

What is going on here?

At this point Qorvis has now reported, in separate filings, that this $45,000 payment came from Vasile Tarlev directly, from ACFHCUM on behalf of Mr. Tarlev, and now from Sam Alaverdov “as per the preference of Mr. Alaverdov” - on behalf of Mr. Tarlev.

To begin with, we can see a consistent level of sloppiness from Qorvis. They have diligently filed their FARA paperwork, and made corrections, but basic facts have been wrong time and again.

It’s also telling that in the latest filing they chose to pin the “need for multiple amendments” on deceased employee Yevgeniy Sydorov. The following is from the FARA filing and screenshot above:

“Mr. Yevgeniy Sydorov who was the Qorvis consultant in charge of the account passed away in October 2024, which has contributed to the need for multiple amendments as we uncovered new information.”

At least they spelled his name correctly, as opposed to their past FARA filings. In that previous supplemental filing Qorvis indicated that Yevgeniy Sydorov terminated his relationship with Mr. Tarlev on October 3rd, 2024, only 4 days after the original contract with ACFHCUM was signed. This date likely corresponds to his tragic passing. Qorvis announced his passing on October 8th.

The choice by Qorvis to blame, even in part, their failure to account for who paid them on October 17th, 2024 on a man who had at that time been dead for 2 weeks does not cover the company in glory. It is also worth noting that these updates only came after multiple stories and requests for comment from Moldova Matters.

Bringing it All Together

After many twists and turns let’s summarize what we learned through this journey point by point:

1. In September 2024 ACFHCUM, represented by director Sam Alaverdov,2 signed a contract agreeing to pay Qorvis $85,000 to represent Vasile Tarlev in Washington DC.

2. Vasile Tarlev never made it to Washington in December 2024 due to visa issues.3 Qorvis conducted limited outreach on his behalf but ultimately concluded the contract and terminated the relationship on March 14, 2025.

3. $45,000 was paid to Qorvis for this contract from Sam Alaverdov personally on October 17th, 2024. When reached for comment as to why his organization was signing this contract Sam previously told Moldova Matters “I like him” before cutting off contact.

In the course of this investigation we’ve identified some major issues, both in process and in substance, with how this business was conducted. Here’s a review of some of those issues and what they could mean:

• Qorvis’ filings had repeated inconsistencies regarding the most core aspects of FARA. The basic purpose of FARA is so that the American people know who is paid to lobby elected leaders on behalf of foreign governments, and what are they doing with that money. For many reasons this contract is not very typical. The principal consultant at Qorvis passed away right after it was signed. The foreign principal never got to the US due to visa issues. The whole contract is *tiny* compared to the sums that Qorvis is used to getting from the House of Saud and other groups. FARA was already a poorly enforced law before the second Trump administration effectively gutted it - most likely Qorvis was simply sloppy because they didn’t find it too important. But the real red flag was right up front - when the House of Saud wants a lobbyist, they hire one. Who and what is ACFHCUM and why is a New York charity hiring them to support Vasile Tarlev? That should have been a question they asked. And if they did they would have found…

• The “American Charity Fund for Helping Children of Ukraine and Moldova Inc” (ACFHCUM) is basically none of those things. Tax filings for the entity show a basically empty shell, one that never raises money or distributes charity. In past reporting we showed that they actually raised some money in the past - for victims of Russian aggression in Ukraine - but somehow none of that money made it to the bank according to tax fillings. They also spent extravagantly to finance the most expensive Congressional Delegation of 2021 - flying 3 US congressmen, their families and some fascinating hangers on, to Ukraine. As in our current case, Sam signed those contracts but ACFHCUM’s tax filings show neither income nor expenses to match. This means that in addition to FARA questions, ACFHCUM has been used in Congressional Ethics Filings as well - also seemingly as a front.

• Sam Alaverdov is the only person we can identify as being linked to ACFHCUM. When reached by Moldova Matters he briefly tried to deny that the organization existed, before admitting to the contract and saying of Vasile Tarlev “I like him.” Putting aside whether or not that is a good reason to spend a supposed children’s charity’s money, there was no money. If Sam paid Qorvis out of pocket last October he was not reimbursed by ACFHCUM in 2024. Unless he was later reimbursed in this tax year, that means that Sam personally paid $45,000 so that Qorvis could send approximately 21 emails asking people if they want to meet with Vasile Tarlev. There’s no reason to believe that Sam is some millionaire donor, Zillow estimates his house, where ACFHCUM is registered, as being worth around $750,000. He must really like Mr. Tarlev indeed.

• Vasile Tarlev didn’t report any of this to the National Integrity Authority (ANI). As the leader of a political party he is required to file yearly declarations of his assets and personal interests. As part of this, any payments or expenses greater than $8000, made by him, or on his behalf, or on behalf of his party, or on behalf of a company or organization affiliated with him, would have to be reported. Mr. Tarlev apparently sought to hide this financial arrangement in Moldova.

• Tarlev’s people targeted me with a smear campaign for writing about this… then they deleted it. They ignored my initial piece, or were unaware of it, until Moldovan investigative journalist Alina Radu wrote an op-ed about connections between Russian politicians in Moldova and the incoming Trump administration. Immediately, a website controlled by Mr. Tarlev’s supporters published smear articles against both her and me. I wrote about that experience here. Later both articles were deleted with no explanation.

Conclusion

Even though Vasile Tarlev’s planned trip to the US was unsuccessful, it is instructive. Over the last year we’ve seen operations conducted by members of Ilan Shor’s network work to spread Kremlin narratives about Moldova in media, via lobbying firms and in the halls of power both in Washington DC and the EU. We’ve been able to report on this story because, despite their faults, Qorvis followed the law and made the required transparency filings. We know for a fact that at least one agent of Shor’s found a firm to represent her in DC that was happy to omit these filings altogether. And we know that a lack of transparency laws like this inside the EU makes it very hard to see how political influence is peddled within the block.

The Tarlev story shows that politicians linked to Ilan Shor are actively trying to establish contacts in Washington. It also highlights the opaque network of people and entities that facilitate the financing of efforts such as this. Sam Alaverdov has largely been unwilling to comment for this story. Without him speaking up, we simply don’t know where he got the $45,000 for this contract.

We also don’t know how many other Sam Alaverdov’s there are out there.

It is well known that Moldova has a serious problem with illicit financing of political parties and activities in the country. The authorities have been in a cat-and-mouse game with the Shor network for years - trying to intercept bags of money, foil crypto schemes and generally prevent them from spreading Russian propaganda and bribing voters.

What isn’t as well known in Moldova is how serious the illicit financing problem is outside of the country. Spotty sanctions enforcement means that the Shor network is consistently able to keep spending money on facebook and other platforms to target Moldova. At the same time, we have little to no insight about the schemes and operations being run outside of Moldova targeting decision makers in Europe and the United States.

This investigation is just one window into a world of laundered money, influence peddling and Russian disinformation going on outside of Moldova’s borders. The purpose of these efforts is to undermine Moldova’s future in the European Union and to further poison the international discourse about the country with Kremlin narratives. This publication originally set out to try and convince readers that Moldova Matters far beyond its borders. Stories like this show that theo Kremlin is convinced.

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Last December, Moldova Matters reported an investigation into how a high powered Washington DC lobbying and public relations firm had signed a contract to represent Moldovan politician and recent presidential hopeful Vasile Tarlev. The contract indicated that a US based non-profit organization called the “American Charity Fund for Helping Children of Ukraine and Moldova Inc” (ACFHCUM1) had agreed to pay the PR firm Qorvis $85,000 for a list of services to enhance the online reputation of Mr. Tarlev, to present him as a “thought leader” and to schedule meetings with policymakers.

Author’s Note: I strongly recommend that you read the original investigation in order for this followup to be comprehensible. You can read that article here:

Following this reporting a number of important questions remained unanswered. What did Mr. Tarlev plan to accomplish under this contract? Why did ACFHCUM agree to spend more money than they had ever raised or spent previously on this effort? Who was the ultimate source of the funding behind this contract?

What we do know is that Vasile Tarlev’s lobbying contract was largely (but not necessarily totally) unsuccessful. Visa issues prevented him from traveling to the United States as planned and no meetings with American lawmakers were held. At the same time, we now know that Moldovan politicians affiliated with fugitive oligarch Ilan Shor have been making similar lobbying trips to Washington DC and at times these have not been reported as legally required under the Foreign Agents Registration Act (FARA2).

So, while Vasile Tarlev is not a major figure in Moldovan politics, we’re diving back into this case with new legal filings to shed some light on the unanswered questions and try to better understand how Moldovan politicians affiliated with Ilan Shor are attempting to sway American policies.

…and most importantly, who’s paying for it.

Part 1: The Money Question

In the previous investigation we analyzed Qorvis’ FARA filing detailing their contract agreeing to represent Mr. Tarlev. The contract stipulated that ACFHCUM would pay Qorvis a retainer fee of $45,000 following the signing of the contract with the balance of $40,000 to be paid on October 10th. At the time we couldn’t confirm whether or not these payments had been made in accordance with the contract because the FARA filing (Exhibit AB) was registered with the US Department of Justice on September 30th, prior to either planned payment being made.

In the last months two new legal filings were made public shining some light on these financial arrangements. The first is the Supplemental FARA filing by Qorvis. This filing was received by the US Department of Justice on April 30, 2025 covering the company’s FARA regulated activities in the 6 month period ending on March 31, 2025. On May 7th Moldova Matters wrote that this filing was unavailable and how the Trump Administration has deprioritized FARA enforcement causing a large decrease in the number of filings being posted online. We now know that Qorvis filed on time3. This filing indicated that the company’s relationship with Mr. Tarlev terminated on March 14, 2025. We’ll get into the details more below.

The second new legal filing is the 2024 tax returns for the “American Charity Fund for Helping Children of Ukraine and Moldova Inc” (ACFHCUM). As a registered 501c4 charity4 they are required to file public tax returns in either Form 990 or Form 990EZ - a short form for smaller NGOs. ACFHCUM filed Form 990EZ and we’ve analyzed their activity, or lack thereof, in 2024.

The Qorvis Supplemental FARA Filing

The supplemental FARA filing made by Qorvis covers a lot of ground. It indicates which employees worked on the contract, what activities they took and it details payments and reimbursements. We’re going to dig into the activities below when we look at what this contract was supposed to accomplish. For now, let’s look at the payment.

In the above table we can see Qorvis’ report on the payments they received in the 6 month period covered by the supplemental. In the last lines Vasile Tarlev is listed as the Foreign Principal supported, and we see the retainer fee of $45,000 that had been listed in the contract as having been paid on October 17, 2024.

Importantly, this filing lists Vasile Tarlev as the person / entity “From Whom” the payment came. We see no record of ACFHCUM, the organization that signed the contract and committed to making these payments on his behalf.

ACFHCUM’s Form 990EZ

Reviewing ACFHCUM’s tax filings for 2024 reveals a pretty straightforward story - the organization reported no activities in 2024.

The organization reported neither income, nor expenses, for the year. The tax documents list a beginning account balance of $1 and an ending balance of $1. So according to these documents ACFHCUM continued its pattern of mostly doing nothing.

On face value these 2 filings would seem to agree with one another. ACFHCUM did not take in donations to support Mr. Tarlev and did not make a payment to Qorvis. At the same time the contract signed by ACFHCUM was (partially) honored by Mr. Tarlev himself. However, there are additional inconsistencies that indicate that this might not be the whole story.

Lots of Ambiguity With the Money

There are a number of issues that complicate the rather straightforward story above. Here are a few of them:

Problem 1: Vasile Tarlev did not report paying Qorvis $45,000. As the leader of the Future of Moldova Party, Tarlev is required to file a “Declaration of Assets and Personal Interests” with Moldova’s National Integrity Authority (ANI) yearly. His 2024 filing, which was completed on March 31, 2025, showed no payments to Qorvis.

I asked Ilie Chirtoaca, President of the Legal Resource Center of Moldova, if such a payment would be required on Mr. Tarlev’s ANI filing. He responded:

"If this payment was made by Vasile Tarlev in October 2024, he is legally required to declare it in 2025. The law is clear on this: any services exceeding the value of 10 average salaries5 must be reported to ANI, as stipulated in Section VII/1 of the asset declaration form."

Payments made on his behalf by entities under his control, or by third parties acting at his direction or for his benefit with his knowledge, are subject to mandatory disclosure under Moldovan asset declaration rules pursuant to Law No. 133/2016 Article 4 (3).

Problem 2: ACFHCUM has a history of ambiguous reporting. As we reported in the previous investigation, ACFHCUM was listed on Congressional Ethics filings as being the primary financial sponsor of a congressional delegation (CODEL) to Ukraine in August 2021. This filing indicated that the NGO spent upwards of $46,000 on the most expensive CODEL of 2021 to bring 3 US congressmen and their family members to Ukraine. This payment was not reported on ACFHCUM form 990EZ tax filings that year. The organization showed no income capable of supporting such an expense and did not report the expense itself.

Problem 3: Qorvis made other mistakes in this FARA supplemental filing. In the filing Qorvis is required to record all activities that they took under the signed contract with the foreign principal. We’ll get into the details of this below but in at least one instance they omitted information that they were legally required to include. To be clear, there is no reason to believe that this was malicious - FARA filings are complex and the US Department of Justice has a long history of not taking FARA too seriously. It is possible that Qorvis made an honest mistake, or that they were a bit sloppy6. This whole relationship is somewhat unusual because the foreign principal, Mr. Tarlev, was being supported by a 3rd party. It is possible that whoever filled out the filing simply listed Tarlev under both the “Foreign Principal” and “From Whom” (payer) portions of the contract by mistake.

Problem 4: Qorvis did not file a revised contract stating that the party paying them had changed. Under FARA Exhibit AB a contract must be amended if there are material changes to the principal, payment terms or scope of the contract. No such amendment has been filed - but Qorvis has been diligent about filing other amendments including minor ones involving Mr. Tarlev. Failing to file an amendment indicating that the party paying for the contract had changed is significant. Assuming a good faith effort by Qorvis this further supports the possibility outlined in Problem 3 that listing Tarlev as the payer was an error.

What Does Everyone Say About This?

Vasile Tarlev did not respond to multiple requests for comment. Sam Alaverdov, Director of ACFHCUM, and signer of the contract with Qorvis similarly did not respond to multiple requests for comment.

An attempt to reach Nina Morozova, the President7 of ACFHCUM, at the phone number listed as her’s on the organization’s tax returns, resulted in some confusion. The phone number appears to belong to a Manhattan based translation firm called Express Language Solutions. Staff there could not recall any Nina Morozova working at the company but directed me to email the CEO for clarification. I did and he did not respond.

A phone call to ACFHCUM’s accounting company, Yevgeny Pisarevsky CPA PC, based in Brooklyn NY, was answered by a woman speaking Russian who hung up when I identified myself as a journalist. In their 11 years of operations, ACFHCUM’s tax returns have always been filed by this company, but ACFHCUM has only once recorded paying for their accounting services - $500 in 2023.

I was able to reach representatives of Qorvis familiar with this contract but they declined to comment.

So Who Funded this PR / Lobby Contract for Vasile Tarlev?

Since none of the involved parties opted to comment, we are unable to untangle the ambiguities that exist in all these disparate filings. At the same time we can essentially identify 2 possible scenarios:

1. Vasile Tarlev paid Qorvis directly. In this scenario the company accurately reported this payment in their Supplemental filing but failed to file updated contracts. Mr. Tarlev did not report this payment, as required by Moldovan law.

2. ACFHCUM paid Qorvis according to the original contract. In this scenario Qorvis had a typo in their Supplemental filing - something that it is still possible that they will amend in the future. ACFHCUM failed to report the source of these funds, or the expense on their tax returns, as required by American law. Unless Mr. Tarlev was ignorant of what was being arranged on his behalf, then this payment could also constitute a reporting event for his ANI filings as it was done to benefit him.

One of these parties paid Qorvis $45,000 for their work on behalf of Mr. Tarlev. That means that one of these parties made a serious omission in other filings that, intentionally or not, obfuscated this payment. Either of these potential omissions is serious, and if intentional, could have serious legal ramifications.

This leaves open the critical question - where did this $45,000 come from. If ACFHCUM paid, then they must have had a donation of the same amount from some other party to cover this expense. If Mr. Tarlev paid, it isn’t entirely clear where he would have gotten this money from. His ANI filings show money and property sufficient to make the payment - provided that he sold some of his assets to do so - but no such sale was reported.

So we are left not knowing who paid, or where the money came from. But we do know that someone is not properly reporting this payment.

Part 2: What Did Qorvis Do for Mr. Tarlev?

According to Qorvis’ Supplemental FARA filing the company represented Vasile Tarlev from the time that someone paid the $45,000 retainer fee on October 17th, 2024 until the relationship was terminated on March 14, 2025. Under Item 12 of the filing Qorvis reports the general description of the “political activity” taken on behalf of Mr. Tarlev as the following:

“Vasile Tarlev: Public relations support; media and congressional outreach”

In a followup amendment to the Supplemental, filed on June 4, 2025 this is amended to:

“Vasile Tarlev: The registrant conducted to various US government officials and world bank officials on behalf of the foreign principal. The registrant advised the foreign principal on us [sic] political sentiment.”

In the section detailing specific actions taken on behalf of Mr. Tarlev Qorvis reports the following:

This list includes 18 emails to "Gauge Interest in Meeting with Vasile Tarlev." They were sent to 2 international institutions, the World Bank and the IMF, one newsroom, the “Washginton [sic] Examiner,” and the offices of 11 members of congress. All initial emails went out on October 31, 2024 with apparent followup contacts with a few respondents.

We’ll take a look at this record of outreach in detail below, but first we need to address the fact that it is incomplete. Following the publication of my first investigation into this contract, Nonresident Senior Fellow at the Atlantic Council Brian Mefford shared an outreach email from Qorvis regarding arranging meetings with Vasile Tarlev. You can see this email here:

This email was also sent on October 31, 2024 - the same day as the others listed in the filing. So in addition to the contacts that were reported, Qorvis reached out to a representative of at least 1 prominent DC think tank. Reaching out to think tanks would be pretty normal under such a contract, which begs the question whether there were other such contacts that were made and not reported. What we can say definitively is that Qorvis missed at least one activity that should have been listed in this section.

It is important to note that whether or not Qorvis got a response from any of this outreach, they are obligated under FARA to report it. It is also important to note that there is no evidence that the company intentionally failed to report contacts.

What is the Purpose of these Contacts?

From the email above we can see that Vasile Tarlev planned to travel to the United States from December 10th to 13th of 2024. The list of emails provided by Qorvis indicates that they were working to identify potential meetings for him when he was in Washington.

The members of congress contacted indicates a pretty bi-partisan outreach plan targeting mostly representatives who are involved in regional security issues. This includes Steve Cohen (D-TN) Co-Chair of the Helsinki Commission, Marcy Kaptur (D-OH) Co-Chair of the Congressional Ukraine Caucus, Mike Lawler (R-NY) and Deborah Ross (D-NC), Co-Chairs of the Congressional Moldova Caucus, and members of the House Foreign Affairs Committee.

Additionally, there is another cluster of contacts from the House Freedom Caucus / MAGA wing of the Republican Party - Troy Nehls (R-TX), Barry Moore (R-AL) and Pat Fallon (R-TX).

Taken together with the outreach to the Atlantic Council, World Bank, IMF and Washington Examiner, the strategy appears to be a broad based approach to burnish Mr. Tarlev’s image as a serious regional player with both political and economic credentials.

$45,000 for 18 (+1) Emails?

While the records above indicate that at least a few of the contacted people or entities responded to the outreach by email, that’s about it. Mr. Tarlev never made it to the US in December and so none of these meetings ever took place. We can assume that this is the reason that the rest of the $40,000 agreed to under this contract was never paid - though that isn’t explicitly stated anywhere. Qorvis lists 4 employees as having worked on this contract, including Maryam Isgandarova who sent the email to Brian Mefford presented above.

Maryam Isgandarova, an Azerbaijani citizen, is listed as being resident in Bern Switzerland. Qorvis has 5 international offices outside of the United States including one in Geneva Switzerland. This is worth noting because it is possible that the company continued to support Mr. Tarlev in outreach to European officials and media after his American trip fell through. Due to the EU having much more opaque transparency regulations around foreign lobbying than the US, we wouldn’t know through public filings whether or not this happened.

In addition to that possibility, and the 18 (+1 at least) emails, Qorvis “advised the foreign principal on us [sic] political sentiment.” Collectively this is what Mr. Tarlev appears to have benefitted from the $45,000 paid either by him or on his behalf.

The Big Picture - What’s This All Mean?

As we have extensively written about at Moldova Matters, starting last year there have been a number of efforts by Moldovan politicians, often little known in Moldova, to access the halls of power in Washington DC. These politicians, including, Vasile Tarlev, Victoria Şapa and Stanislav Pavlovschi, all have previously reported links to sanctioned fugitive oligarch Ilan Shor, and appear to be involved in public outreach campaigns in the West. We cannot say definitively who is funding these efforts, but it is clear that there are serious reporting discrepancies and ambiguities around the financing of these campaigns. Ambiguities that, in some cases, should not exist under either American or Moldovan law.

Moldova Matters will continue to monitor such outreach by Shor affiliated characters in the West. If you have a tip you’d like to share, feel free to respond to this email and get in touch.

Back in December 2024 I published an investigation showing how Moldovan presidential hopeful and Shor-linked politician Vasile Tarlev had contracted a PR and lobbying firm in Washington DC. The firm is called Qorvis and the $85,000 dollar contract outlined planned work around reputation management, meetings with decision makers, policymakers and promoting Tarlev as a “thought leader.”

In addition to the contract details, the investigation followed the money and looked at how a small time New York NGO with nearly no fundraising or spending had somehow financed this contract on behalf of Mr. Tarlev. If you haven’t read the original investigation I suggest taking a look at it - here’s a link:

After publication, there was initially no public reaction to my investigation in Moldova until Investigative Newspaper ZdG cited it in an editorial focusing on how Moldovan politicians have been trying to cozy up to Donald Trump. That ZdG article caused some blowback with a Tarlev-linked online publication publishing smear article against me and against the ZdG editor Alina Radu. I detailed that process in an article back in January.

Now it’s time to check in. Qorvis is legally required to file public documentation under the Foreign Agents Registration Act (FARA) that details how this money was spent and what they did on behalf of Mr. Tarlev. That filing was due 6 months after the initial FARA filing - aka March 30, 2025. As of today (May 7th) there is no filing from Qorvis on the Department of Justice website and the contract is marked as “active.”

How Does FARA Work?

Under the Foreign Agents Registration Act companies or individuals acting as an “agent” of a foreign principal (governments, companies, individuals, etc) who are engaged in lobbying, PR, information campaigns, etc are required to register and report on their activities. This involves an initial registration and transparency filings with the Justice Department and then periodic updates. Qorvis made their first filing regarding Mr. Tarlev on September 30, 2024 - you can view it here.

Following this initial filing Qorvis is required to file a supplemental statement (Form NS-2) every 6 months. If they close the contract they need to file a supplemental statement indicating that the contract is no longer active. Additionally, if they conducted any informational campaigns targeting more than one person they would have had to make an additional filing within 48 hours of those materials (press release, etc) going live. There are no records of any of these filings being made.

If Qorvis missed the filing they could face both civil and criminal charges. FARA has long been a problematic law with poor enforcement - but it does have teeth. It’s not uncommon for someone working as a foreign agent to fail to register. It is stranger to file the initial registration and then not to follow up.

What’s Going On Here?

There are basically 3 possible reasons that there isn’t an updated filing on the Justice Department website:

1. Qorvis failed to file the documents

2. Qorvis did file, but the website had not been updated yet

3. Qorvis did file, but due to some clerical error or other issue the document has not been released or is being worked on.

Typically, FARA filings appear online within a few days - even when they are delayed. With this filing over a month late this possibility appears unlikely - but it remains a possibility.

I have made multiple attempts to reach Qorvis for comment and have not heard back at the time of writing. If they do respond this article will be updated.

In order to better understand what was going on I reached out to Casey Michel, author of Foreign Agents: How American Lobbyists and Lawmakers Threaten Democracy Around the World and the Director of the Combating Kleptocracy Program at the Human Rights Foundation. I asked Casey if it is typical for filings to be this late and he replied:

“The filing system for foreign lobbying has faced issues for years, not least when it comes to enforcement. Sometimes. a filing is missing for perfectly benign reasons - maybe there's an issue with a file, or there are questions about the details in the filing. But as we've seen with recent prosecutions, there are also very malign reasons that filings are missed - primarily because the lobbyist and their client don't want transparency into their operations”

He explained how the policies of the Trump Administration might be the behind the lack of a filing writing:

“It's clear that the current administration has deprioritized transparency when it comes to American lobbyists working directly for foreign regimes or foreign officials, including in the most kleptocratic regimes around the world. The administration has instead announced that it will focus on transparency for lobbyists working for cartels - though after a decade of working on this topic, I can't say I've ever seen a single cartel hire a single lobbyist. It's unclear why this specific disclosure is missing - but it's also clear that filings have dropped across the board, because of the administration's recent directive that they won't enforce basic foreign transparency regulations.”

What Casey is referencing here is the fact that US Attorney General Pam Bondi directed the Department of Justice to limit enforcement of FARA to “to alleged conduct similar to more traditional espionage by foreign government actors.” Bondi, who was herself a registered foreign agent of the nation of Qatar before taking her current position, has effectively eliminated enforcement of FARA for political lobbying and information campaigns.

At the same time, choosing not to enforce a law, or not to prioritize it, does not make it any less of a law. Casey explained:

“there's generally a five-year statute of limitations on foreign lobbying filings, so if you're a foreign lobbyist trying to improve the reputation of a client for American audiences, you should absolutely be filing this paperwork. It's entirely possible that a future administration will take a close look at all those lobbyists who've failed to report their work [for] Tarlev, and have plenty of questions about where the paperwork is.”

Since Attorney General Bondi’s directive, FARA filings have fallen by more than 30%. At the same time, press reports indicate that the Trump administration is effectively a pay-for-play lobbying bonanza. So if Qorvis just decided not to bother with transparency filings anymore they would not be alone - but they could face consequences down the road.

So what did they do on behalf of Tarlev?

Without the FARA filing we cannot be certain what happened to that $85,000 exactly. But we do know a bit. My reporting has confirmed that Vasile Tarlev never even got to the United States for his meetings with lawmakers and think-tanks. Visa issues forced him to cancel the trip. There have also been no public campaigns or press releases bigging-up Tarlev in the United States. So the answer to what Qorvis did for Tarlev in DC might be “nothing.”

Qorvis is a global firm with an office in Geneva, Switzerland in addition to Washington. It is possible that the firm shifted to supporting Tarlev in Europe given his visa problems. Unfortunately, the EU’s lax lobbying and transparency regulations mean that we can’t get any insight into whether this happened or what the outcome might have been. Emma Marechal has previously written for Moldova Matters about the EU’s lobbying loopholes in a different investigation targeting Shor’s lobbying efforts in DC and Brussels. You can read it here:

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Influence in the Trump Era

Back in December I wrote a piece about the dangers of Kremlin influence campaigns in the second Trump administration. In that article, I anticipated some of the changes that were coming (e.g. changes to USAID) and discussed how vulnerable a small country like Moldova is to elite level influence campaigns. I also used the article to write a review of Casey Michel’s excellent book Foreign Agents:

With Trump’s return to office, the dismantling of USAID, the dismantling of the Global Engagement Center1 and the bonanza of lobbying and influence peddling it is now clear that the problem was real - but the scope was larger than I could have imagined. Romanian presidential hopeful George Simion missed precious campaign time to head to Washington and appear on MAGA podcasts. His $1.5 million dollar lobbying contract was filed properly under FARA. It is unclear why Qorvis missed their filing. What is clear is that under the current administration there will both be an unprecedented level of foreign lobbying, and an unprecedented lack of transparency.

This issue of Moldova Matters is supported by Rotary Club Cosmopolitan — Club Secretary Luc Vocks invites you to join an English-speaking (mostly) expat club that meets weekly to hear from engaging speakers and enjoy some light networking. If you're curious to learn more or would like to attend a meeting as a guest, feel free to contact l.vocks@developmentaid.org.

Shor, who is sanctioned by the EU, US, UK, and Canada for his role in Moldova’s largest financial fraud and for destabilizing the country’s political system, remains politically active from exile in Moscow. His associates, like Şapa, are now seeking political influence outside of Moldova:  As  Moldova Matters has reported, Fortius Consulting is representing Ms Şapa in the US. The consultancy’s activities promoting narratives about Moldova that align with the Shor-agenda suggest that they are also pursuing lobbying and media influence for Shor affiliates in the EU. 

This investigation explores Fortius Consulting’s connections to Victoria Şapa and the hard-right ‘Make Europe Great Again’ (MEGA) movement, its role in shaping narratives about Moldova’s elections, and the legal loopholes that allow sanctioned individuals like Ilan Shor to continue political lobbying in the EU.

Who’s who: the key players 

• Ilan Shor is a pro-Russian oligarch sentenced for his role in the theft of over one billion dollars from 3 Moldovan banks. He is currently residing in Moscow, from where he coordinates electoral interference in Moldova - engaging in activities that range from vote buying and organizing protests, to perpetuating disinformation through Shor-owned channels. 

• Victoria Şapa is a childhood friend of Shor, and ran for mayor in Balti as part of Shor’s Chance party, before it was disbarred from running in elections. 

• Fortius Consulting is a Madrid-based strategic public relations (PR) and lobbying firm founded by Juan Angel Soto Gomez, a conservative strategist deeply connected to Europe’s hard-right political movements. 

What is Fortius Consulting, and who is behind it? 

The little-known consultancy firm was ostensibly founded in 2015. Offline and online activities seem to have picked up from 2023 onwards, and most hiring occurred in the last year. Fortius Consulting specializes in “strategic communication and social mobilization,” which essentially boils down to communication or media campaigns, networking and advocacy. In practice, this means working with right-wing political actors and organizations that advocate nationalist, populist, and conservative policies.

Its founder, Juan Ángel Soto Gómez, has deep ties to Europe’s hard-right ecosystem. He has spoken at multiple Conservative Political Action Conferences (CPAC)1, as well as the ‘Make Europe Great Again’ Conference organized by the European Conservatives and Reformists Group (ECR) and Romania’s hard-right Alliance for Romania (AUR) (which embraced the now-barred ultranationalist presidential candidate Calin Georgescu). He was in Washington DC for Donald Trump’s recent inauguration and attended the Hispanic Inaugural Ball. 

Mr. Soto has previously worked as International Director at the Disenso Foundation2, a conservative think tank whose president is Santiago Abascal, leader of Spain’s nationalist Vox Party and of the hard-right Patriots of Europe3. The latter is a new European party group that unites the likes of Hungary’s Viktor Orbán, France’s Marine Le Pen, and the Netherlands’ Geert Wilders. Soto’s latest appearances indicate that Fortius is well plugged into these circles, with transnational connections that span various far-right political parties across Europe. 

Fortius, Moldova, and the Disinformation Ecosystem

Fortius Consulting’s links to Moldova first surfaced when Soto published an op-ed in El Debate on October 19th 2024, questioning the legitimacy of Moldova’s elections and its EU accession process. These criticisms were based on the claim that the Moldovan government barred European NGOs from monitoring the elections in the fall4. From this, he extrapolates that the Moldovan elections and democracy lack integrity. He further argues that the EU is straying from its democratic nature and exhibits selectivity:  ”applying sanctions or severe measures in some cases, [while] in others it turns a blind eye to clear signs of democratic weakening”. 

A day before Soto’s article, EU Reporter’s Colin Stevens shared the article “Moldova’s Election Commission blocks European observers ahead of crucial EU accession referendum”. The following day, EU Today’s Gary Cartwright published a nearly indistinguishable article entitled “Moldova’s Exclusion of International Election Observers Raises Concerns Ahead of Pivotal 2024 Elections”.  The timing of Soto’s article—published the same day as similar reports in EU Reporter and EU Today, both outlets known for “pay-to-play” lobbying practices—suggests a coordinated effort.

A 2021 three-part investigation by Politico identified EU Reporter and EU Today, and their respective founders Colin Stevens and Gary Cartwright, as engaging in murky practices of “EU lobbying dressed up as journalism.” The two Brits are closely connected, often amplifying each other’s content to foster the impression of legitimacy and wide circulation. Moldova Matters has previously written about how PR companies affiliated with Shor have circulated disinformation via these media outlets. 

The Atlantic Council’s Digital Forensics Lab (DFRLab) has already picked up on this very cluster of articles undercutting the integrity of the Moldovan election, identifying EU Reporter and EU Today as “alternative European media spread[ing] pro-Kremlin narratives” and disinformation. As Daniela Calmis tracked, the story was subsequently picked up by eleven networks, in six different languages. 

In 2024 alone, EU Reporter published 24 PR-planted pieces (undeclared as such) about Moldova, concerning Shor or his affiliates. This includes an open letter “written by politicians representing a wide spectrum of the opposition in Moldova” - in actuality the majority representatives of Shor parties. The letter, addressing European institutions - decries the “unimaginable dictatorship” in Moldova under the PAS government and denounces the disbarring of Shor-affiliated parties. The twelfth and last signatory was Victoria Şapa.

In his article Soto failed to mention one important point - his own association with half of the supposedly excluded NGOs. 

The criticism on which this entire cluster of articles is based comes down to the claim that the Central Election Commission (CEC) blocked various European NGOs from observing the elections in polling stations in Europe installed for the diaspora. Further investigation shows that at least four of the eight NGOs that claimed to be “blocked” from election observation were directly linked to Soto. These include:

1. Fortius Foundation (founded by Soto)

2. Principios Foundation (founded by Soto)

3. Fundación Sociedad Civil (led by Soto)

4. Trezeno Institute (where Soto is an affiliate)

The other NGOs listed were the Académie de Géopolitique de Paris; The International Centre for Relations & Diplomacy; History Heritage Humanity; and Together for Future in Georgia. The latter has stopped working.  Taking a closer look at the NGOs listed, DFRLab concluded that “many could not be identified online, some had been inactive for several years, and others, while still operational, did not publicly indicate any interest in monitoring the elections in Moldova.”

When contacted by Moldova Matters for clarification, Pavel Postica, deputy Chairmen of the CEC, acknowledged the receipt of the NGO’s applications. However, he stated that these were submitted shortly before the elections and they also failed to provide proof of electoral observation experience.  This meant that they did not pass the preliminary verification stage.  

Typically the CEC invites international organizations to observe elections in Moldova. They do take unsolicited applications and according to Postica evaluate them based on the applicant’s history of conducting successful observation missions and the organization’s financial transparency. Since these NGOs did not provide key information their applications were essentially incomplete. 

Fotrius Consulting did not reply to multiple requests for comment regarding their representation of Victoria Şapa or details of their agreements to represent figures linked to Ilan Shor.

These applications to observe the elections were therefore at best a long shot and at worst spurious. Their failure neatly set up a disinformation effort, which Soto clearly participated in, to discredit the elections themselves. 

The EU’s Lobbying Loopholes and Sanctions Gaps

While Shor remains under sanctions, neither EU lobbying rules nor the sanctions regime itself prevent European firms from working with him, his associates or promoting his interests. The EU regulatory framework is porous, marked by loopholes that allow activities like those conducted by Fortius to take place. 

Loophole 1: Weak lobbying regulations, inexistent PR rules 

Lobbying in the EU is notoriously intransparent. The EU introduced a Transparency Register demanding obligatory registration of any individual or entity, European or foreign, seeking to access and influence European institutions. The Fortius Foundation, as well as several of the entities listed as past partners or clients, are listed in the Register. However, the world of lobbying far bypasses this official channel. Public relations, social media and communication campaigns are critical levers of political influence by shaping public attitudes and discourse. MEGA is aware of the power of this - first on the agenda at the 2025 MEGA Conference was a discussion on “New Media Channels and their influence on politics and elections”. EU legislation, however, has not quite caught up: Unlike their American counterparts, where a Foreign Agent Registration Act filing has to be declared for any foreign individual, firm or government seeking to engage in lobbying, public relations, media or other activities seeking to influence policy or debate on American soil - Europe does not keep a tab on this. 

The albeit rudimentary transparency requirements in place for direct lobbying to institutions  transparency don’t exist for PR activities. If the reins are loose when it comes to lobbying, they don’t exist for PR firms or disinformation campaigns. No legal requirement exists in the EU laws that demands disclaimers to notify when content was paid for, to facilitate readers ability to distinguish between paid-for PR plants and independent journalistic content. Rather, it is left up to journalists’ own ethical codes, to which they choose to voluntarily abide, or not.  

Loophole 2:  EU basic sanctions regimes permit services for sanctioned individuals

Under the current EU sanctions regime on Moldova, Shor’s funds are frozen but he is not prevented from hiring consultants or influencing EU public opinion through intermediaries like Fortius. This is in contrast to US sanctions against Shor which are far more robust and include asset freezes, a ban on transacting with Shor or the Shor Party, travel restrictions and mechanisms for applying secondary sanctions against those attempting to undermine the sanctions regime5.

The EU sanctions against Shor stand in stark contrast to the elaborate 16-package sanctions regime imposed on Russia. In 2023 the EU erected a basic targeted sanctions regime towards specific Moldovan nationals “destabilising” the country. This regime is one-dimensional, only entailing the freezing of funds. It prohibits sanctioned individuals from accessing, transferring, moving or using any funds they have in the EU. Enforcement entails checking whether individuals aim to circumvent the ruling to get their hands on the funds anyways. They, however, remain free to enlist whichever services they desire in the EU - from legal services, to lobbying, to PR, as long as they steer clear of their frozen assets. While those under Russia sanctions are slathered with “multidimensional” restrictions including a prohibition on goods, services, imports and exports, as well as a travel ban and asset freeze, Moldovan citizens like Shor are only subjected to the latter. The road for political lobbying is left wide open for sanctioned Moldovan individuals, not to mention their affiliates. 

To mark the three-year ‘anniversary’ of the Russo-Ukrainian war on the 24th of February, the EU further fleshed out the Russian sanctions regime with the latest package. 48 individuals and 35 entities “responsible for actions undermining or threatening the territorial integrity, sovereignty and independence of Ukraine” were added. This included targeting “third country nationals that supported the Russian war effort” (e.g. Chinese satellite imagery producers), and “actors responsible for circumventing EU sanctions, including through third countries.” It also took into account the risk of Russian propaganda:

“Responding to Russian propaganda remains also a priority. Alongside notorious Russian propagandists, the EU is notably listing NewsFront, and SouthFront, two outlets presenting distorted interpretations of history and manipulated information in line with Kremlin messaging while also targeting European and global audiences with distorted and manipulated information.” 

Ilan Shor was not among the 48 new names. What this means is that he remains solely subjected to the basic sanction mechanism surrounding asset freezes. That is, despite his overt and well-established ties to Russia and his history of propelling ‘distorted information,’ he and other “pro-Russian actors” from Moldova, condemned by the EU, continue to enjoy a wide range of freedoms in the EU. Were Shor to be added under the Russian sanctions regime, it would be a different story. 

In sum  

Ilan Shor’s PR operations highlight how pro-Russian actors can and do operate within the EU’s lobbying ecosystem, to influence policy-makers and shape public opinion. This highlights a major gap in the EU lobbying, PR and sanctions legislation. PR and consulting companies representing Shor affiliates and participating in pro-Shor media campaigns, do not as such breach the law.

Despite spreading disinformation and mobilizing ethically questionable journalism, whether paid for by a sanctioned individual or their affiliates, the existing legal framework provides little to no restriction on such operations.

While the EU is straining to counter disinformation and foreign influence, it lacks a comprehensive framework to track and regulate the activities of PR and lobbying firms. 

This story was reported and written by Emma Marechal. It was edited by David Smith.

Fortius reached out to arrange meetings with the following profile description of their client.

In addition to any meetings arranged by Fortius, Victoria Şapa was in Washington with the intention to attend the annual Conservative Political Action Conference (CPAC). She has made no social media posts or public statements about her visit or activities so it is unclear if she did attend CPAC or whether Fortius was successful in arranging meetings for her. Neither Victoria Şapa nor Fortius Consulting responded to multiple requests for comment. As of the time of writing there is no publicly available Foreign Agents Registration Act (FARA) filing regarding the services and activities that Fortius is providing to Şapa1.

Who is Victoria Şapa?

Back in Fall 2023 Ilan Shor was determined to contest the election for mayor of Balti. His primary candidate, Marina Tauber, was not allowed to run due to the decision that summer declaring the Shor Party unconstitutional, which contributed to her registration as a candidate being rejected. In order to hedge against his candidates being removed from the race Shor ran 6 candidates in this election - one of whom was Victoria Şapa.

Ms. Şapa was a candidate for the Chance Party and was removed from the race right before the election along with all other Chance candidates across the country. I covered these dramatic events in detail at the time:

While her official political career was short lived, Victoria Şapa isn’t just a minor regional figure in the Shor network. She grew up with Ilan Shor and Marina Tauber and has been friends with them since childhood.

Last April Ms. Şapa traveled to Moscow to attend the launch of Shor’s new political block - Pobeda (Victory). At the event she was seated in the front row with Ilan Shor, Bashkan Evghenia Gutsul, Marina Tauber, Alexei Lunga (leader of the Chance Party) and other top Shor leaders.

Upon returning to Moldova following the event Ms. Şapa was briefly detained and searched at the airport before being released. Police seized over 20 million lei from other Shor activists returning from the event but found nothing illegal on Ms. Şapa.

Why is She in DC?

As we’ve covered in past investigations2 at Moldova Matters the Shor network is increasingly spending effort and resources in an attempt to sway American politicians and foreign policy professionals. While we don’t know what message Ms. Şapa may have conveyed in whatever meetings that she may have had, past campaigns indicate that Shor has tried to lobby for sanctions relief. He has also sought to paint Moldova as place where free speech is in jeopardy - code for lobbying for the return of Russian propaganda channels to the airwaves.

While we don’t know why she specifically was sent to DC, one possibility is that it wasn’t a long journey for her. Victoria Şapa has lived outside of Moldova for most of the last 17 years, first in Canada and most recently in Miami. It’s unclear if she is an American or Canadian citizen, but she certainly has rights of residency and unhindered entrance into the United States. Past attempts by Shor agents such as Vasilie Tarlev have stumbled due to his inability to get a visa.

She is married to Russian citizen Oleg Semenov. Both Ms. Şapa and Mr. Semenov work as real estate agents.

Victoria Şapa’s Complex Finances

When running for mayor Victoria Şapa filed an income and asset declaration with the National Integrity Authority (ANI). In this declaration, which covered January - December 2022, she indicated a salary of approximately $25,000 from Remax, dividends of $125,000 paid to her husband from his business, a house and an apartment collectively valued at approximately $1.2 million Canadian dollars. She also declared a car and a bank account with $38,000 Canadian dollars in cash.

Investigative journalists at RISE Moldova profiled Şapa at the time and did not report any findings contradicting that declaration. Since that time, new information has come to light which we’re reporting here for the first time in Moldova Matters.

In September 2024 Oleg Semenov and Victoria Şapa filed a lawsuit against a man named Alex Genin who they accuse of “egregiously” mismanaging their finances. The suit alleges that Oleg Semenov opened a brokerage account with Wells Fargo at the urging of Mr. Genin who would act as his financial advisor and investment manager. In early 2020 Oleg Semenov funded this account with $1,285,000 dollars in cash. Later, in September 2021 Oleg Semenov introduced Victoria Şapa to Mr. Genin and she gave him the password to her brokerage account. The suit alleges that Ms. Şapa had funded the account with $80,000 which it calls her “life savings.”

The lawsuit goes on to allege that the pair were unaware of Mr. Genin’s past reprimands from the SEC for trading unregistered securities, engaging in pump-and-dump schemes and trading penny stocks. Over the period of May 2020 to April 2022 Mr. Genin engaged in a frenzy of high volume trading in penny stocks and meme stocks. He invested Ms. Şapa’s money in Canadian Cannabis holdings and other high risk stocks.

When the dust settled Ms. Şapa’s $80,000 had been reduced to $18,356 (November 2022) and Mr. Semenov was left holding a bizarre and extremely high risk portfolio with a value of approximately $144,0003 (June 2023).

Aside from serving as a cautionary tale, this court filing is significant because none of these investment accounts or stock holdings were reported in Şapa’s ANI declaration covering 2022.

According to Ilie Chirtoacă, Executive Director of the Legal Resources Center in Moldova (CRJM), Victoria Şapa “was legally required to declare the investment, with no exceptions.” He noted that even if the foreign brokerage account was solely in her husband’s name it falls under the legal reporting requirements for public officials and candidates. Declarations are subject to a reporting threshold set at 15 times the average monthly salary. For 2022 this would have meant that any assets with a value greater than around $7500 would need to be declared. If the basic facts of Oleg Semenov and Victoria Şapa’s lawsuit are accurate then they omitted assets considerably greater than this threshold from her filing.

According to Chirtoacă, the National Integrity Authority has 3 years from the date of filing to open an investigation into such reports - meaning that the statute of limitation on such an investigation extends to September 2026.

Penalties for omissions on ANI declarations vary widely based on whether there was an intention to omit information and the magnitude of the omission. Typically such investigations for someone who was not elected to office may involve a fine and prohibition from holding public office for a period of time.

Victoria Şapa did not respond to multiple requests for comment.

What is Fortius Consulting?

Fortius is a small strategic consultancy company based in Madrid. It is led by CEO Juan Angel Soto Gomez who is a very active figure at right-wing conferences and MEGA events across Europe, but who has few clear links to Moldova.

In Part 2 of our investigation we will take a deeper dive into Fortius and examine how the company that represents Ilan Shor’s interests in Washington fits into the larger geopolitical moment.

This story was reported by David Smith with research assistance from Emma Marechal. It was written by David Smith.

The firm is Qorvis Holding Inc. and they signed an $85,000 contract in support of Mr. Tarlev on September 6th 2024. In compliance with the Foreign Agents Registration Act (FARA), Qorvis filed details about this contract with the Department of Justice.

This put Mr. Tarlev in an elite group of the prestigious firm’s clients who, in this reporting period, include the Kingdom of Saudi Arabia, government of Cambodia, Republic of Equatorial Guinea and others.

According to the contract the firm was to provide Mr. Tarlev with the following services over a proposed 8 week program (with the option to extend):

Under the proposed 8-week plan the firm would research Mr. Tarlev’s reputation and develop strategies for messaging and outreach to US Officials, Members of the House of Representatives and US Senate.

Qorvis received a $45,000 retainer fee on September 30th and was due to be paid the balance of $40,000 on October 10th.1

As part of Moldova Matters’ previous investigation into the foreign influence efforts of Stanislav Pavlovschi I contacted various US think tanks and found no indication that Mr. Tarlev had any meetings with them. Further, at least from public media, there is no indication that Mr. Tarlev ever made his planned trip to the US for high level meetings. Qorvis is a global firm and it is possible that priorities have changed and they are supporting him in the EU or elsewhere. Until additional filings are made or other facts come to light we cannot know what Mr. Tarlev has actually done under this contract.

What we can do is look into who signed an $85,000 contract on his behalf. But first…

Who is Vasilie Tarlev?

This was the question that had Moldova buzzing last June when Tarlev announced that he would be running for president as an independent. Tarlev had previously served as prime minister of Moldova from 2001 - 2008 under Voronin’s Communist government before beginning a long slide into political obscurity.

While prime minister Tarlev was a major support of closer ties with Russia and was decorated by Vladimir Putin with the “Order of Friendship” for:

"great contribution to the development of economic, humanitarian and business collaboration with the Russian Federation"

In 2012 he founded the “Renaissance" Party, leading it in the 2014 parliamentary elections and garnering 0% of the vote. He then tried to run for president in 2016 but did not gather enough signatures for ballot access.

In the years since, Tarlev disappeared from the political scene as his Renaissance Party became defunct and then was “acquired” by fugitive oligarch Ilan Shor. Under new management Renaissance gathered unto itself defecting Socialist Party MPs and became one of the core parties of Shor’s “Pobeda” (Victory) block.

Tarlev’s plan to run as an independent in 2024 was quashed by the Central Election Commission (CEC) which found him to be coordinating with the “Future of Moldova” party (which he also founded) and forced him to run under that branding.

As soon as he announced, Moldovan journalists began to find ties between Tarlev’s political resurgence and Ilan Shor. Newsmaker reported that Tarlev was chosen from a list of candidates Shor was considering supporting in the election and that his candidacy was decided in Moscow. His own party’s vice president asserted that Tarlev had joined Shor. During the campaign, investigative outlet CU Sens infiltrated parts of Shor’s voter bribery network and discovered that participants in Tarlev events were being illegally paid to be there. Tarlev denies any links to Ilan Shor

Tarlev ended the election with 3.19% of the vote. His campaign was reported to be over 500,000 lei in debt with the CEC referring questions about his campaign finance to Anti-Corruption Prosecutors.

So Who Paid Qorvis?

While it would be completely legal for Mr. Tarlev or his political party to pay Qorvis directly for these services they did not. Instead he has benefited from the support of a US based non-profit originally called the “American Charity Fund for Helping Children of Pridnestrovie and Moldova Inc.” (Pridnestrovie is the Russian name for Transnistria). This non-profit publicly rebranded in 2021 as the “American Charity Fund for Helping Children of Ukraine and Moldova Inc.” As such it goes by the rather clunky acronym ACFHCUM.

According to their website the organization was “established in 2014 after the conflict in Eastern Ukraine” and is “devoted to provide [sic] opportunities to young people in Ukraine and Moldova region.” They list their goals as supporting children’s education, preventing young people from being involved in illegal activities and setting:

“meetings with Government Officials, Cultural, Civic and Business Leaders to present the importance of the region to strategic U.S interests and explore potential avenues of cooperation between the region and the U.S.”

While the organization was formed in 2014 there was no mention of Ukraine in either their name or their mission at that time. There was also no mention of government contacts at that time with their original primary goals stated in non-profit tax filings as:

"Provide for the children of Prednestrovie and Moldova funds for daycares, schools and children's hospitals."

"Organize for the children of Pridnestrovoie and Moldova fun events and trips"

ACFHCUM lists 3 officers in their organization, Nina Morozova (President), Sam Alaverdov (Director) and Olga Morozova (Director).

The organization is registered at 33 Laurel Hill Dr, Valley Stream, NY 11581, USA which is also the home address of Sam Alaverdov. Mr. Alaverdov is listed as the primary contact for the organization on their website, facebook page and other public materials.

Why is ACFHCUM funding Vasilie Tarlev?

In order to better understand the relationship between this non-profit and Mr. Tarlev I sent emails with questions to Sam Alaverdov and to Olga Morozova. I was unable to find public contacts for Nina Morozova who appears to be Olga’s elderly mother.

Neither director responded to my email but I was able to reach Sam Alaverdov via Telegram. After introducing myself and Moldova Matters I asked him why the “American Charity Fund for Helping Children of Pridnestrovie and Moldova Inc.” was financing a PR contract for Vasilie Tarlev. Mr. Alaverdov initially claimed that ACFHCUM no longer exists.

After his initial claim that the non-profit no longer exists, and apparent attempt to deny the FARA filing, I sent Mr. Alaverdov a screen shot of his name and signature on the contract. He then told me I need to “Check the name of the company” to which I replied with screenshots of ACFHCUM’s name, address, his title, etc.

Note: It was possible that Mr. Alaverdov was referring to the name change where “Prednestrovie” was removed and “Ukraine” added. This did not actually constitute a change of company or legal entity in any way.

After this Mr. Alaverdov confirmed that this was him referenced in the contract. Asked why ACFHCUM was funding Mr. Tarlev he replied “I like him.”

Mr. Alaverdov refused to answer questions about the source of the money ACFHCUM was spending on Mr. Tarlev except when I asked whether the money came from outside the United States, to which he answered “No.”

After this he stopped answering questions and deleted his profile picture on Telegram.

Digging into The American Charity Fund for Helping Children of Pridnestrovie and Moldova Inc.

To try and understand why ACFHCUM chose to support Vasilie Tarlev’s PR campaign and where this funding originated from I took a closer look at this non-profit. This revealed a fairly unusual operational history, but before we get into that we need to look at some basics of how American non-profits are legally structured.

When most people think of a non-profit NGO in the US you are thinking of a 501c3 registered entity. 501c3’s are traditional charities or non-profit religious, educational, or scientific institutions. Their purpose is to support the general public and they are not required to pay federal income taxes. Additionally, donations to a 501c3 are tax-exempt meaning that donors get a tax write off for making donations.

The original 2014 goals of ACFHCUM are firmly within the normal uses of a 501c3 - gathering funds to support Moldovan and Transnistrian children, organizing kids events, etc. And between 2014 and 2020 ACFHCUM filed their form 990EZ IRS reports indicating that they are a 501c3 entity.

In these years ACFHCUM largely did nothing. In every year except 2019 they reported $0 raised, $0 spent or donated every year. The one exception was 2019 when ACFHCUM reported that they received $15,000 in “contributions, gifts, grants or similar” and they spent $15,000 in “professional fees and other payment to independent contractors.”

So in the early years of this non-profit they made no charitable donations and recorded only this one in-and-out donation and payment.

Changing the Non-Profit Focus

In ACFHCUM’s 2021 filing of form 990EZ there is an important change. The non-profit no longer lists itself as a 501c3 entity but is now listed as a 501c4. Unlike a 501c3 this organizational form has a mission of promoting social welfare which can include lobby and advocacy work, as well as some types of political activity, so long as they advance their social welfare mission. Importantly, while a 501c4 is exempt from Federal income taxes, donors to such an organization do not themselves get a tax write-off. This makes raising money through a 501c4 for charitable donations (e.g. funding a children’s hospital) much harder as the structure is not designed for it. This filing also reflected their name change.

In the years that follow ACFHCUM’s IRS 990EZ fillings show a very similar situation as before. There are neither donations nor expenditures in either 2021 or 2022 listed - an important issue that we will return to below. In 2023 they list $17,000 in “program service revenue” and $10,000 in payments of “professional fees and other payment to independent contractors.” An additional $6,974 are listed as other expenses, the bulk of which, $5,936 is categorized as “Automobile & Travel Expenses” and the rest is filing fees and accounting. The remaining $26 of the $17,000 is offset by a $25 debt from bank fees back in 2019 resulting in a net result of $1 on the balance sheet at the end of the year.

Taken together we have a non-profit that is mostly inactive except in 2 years when it receives income and expenses that neatly cancel each other out. There is no record of donations towards any of the causes that they claim that they support.2 The shift to a 501c4 would allow the support for Vasilie Tarlev if it is in line with their mission but there is no record in their tax filings indicating that they have done anything like this before.

But they have. Which gets us to some major discrepancies in the official tax filings of ACFHCUM - and some increasing and strange turns in this story.

2021 Congressional Delegation to Ukraine

In August 2021 a 501c3 organization called The Humpty Dumpty Institute (HDI) organized a congressional delegation (CODEL) to Ukraine. According to their press release the purpose of the trip was for the US congressmen to “get a better understanding of the complexities of the region through meetings with the Ukrainian government, business, and cultural leaders.” The trip was attended by Rep. Tony Gonzales (R-TX), Rep. Barry Moore (R-AL) and Rep. Troy Nehls (R-TX).

In addition to the congressmen, Sam Alaverdov attended the CODEL and can be seen in the left of the picture above.

According to trip filings with the House Committee on Ethics3 the American Charity Fund for Helping Children of Pridnestrovie and Moldova Inc. is listed as a secondary sponsor of the trip (under the old name). The Humpty Dumpty Institute was the primary trip sponsor with organizational responsibilities. They accepted a grant / donation from ACFHCUM in order to finance the trip as a secondary trip sponsor. A third sponsor is listed as the company Noosphere Ventures L.P. which provided in-kind support.

On these disclosure forms Sam Alaverdov claims that ACFHCUM is a 501c3 organization4 and that it has given a grant to HDI for organizing this trip. A press release about this CODEL is the only actual activity that is listed on the ACFHCUM website.

Referring to information we have already discussed above, ACFHCUM claimed neither income nor expenses in 2021 on their official tax filings. This CODEL was noted at the time as the most expensive of the year with costs for the congressmen and their wives / friends alone totaling more than $46,000. That is in addition to Sam Alaverdov’s travel and lodging as well as the HDI staff.

Sam Alaverdov, ACFHCUM and HDI all claim that the financing, in whole or part, came from ACFHCUM - but they did not report it in their available public filings.

Note: I wasn’t the first person to ask Mr. Alaverdov about this and there’s a bit more of a story around this CODEL but it goes outside of the remit of this article. I’ll leave a lengthy digression on this topic and the various controversies and characters in a footnote.5

Fundraising in Support of Ukrainians

Following the outbreak of the full scale invasion ACFHCUM setup a facebook page and a fundraiser on Fundly to raise money for “the citizens and children of Ukraine.” On the facebook page they claimed that they will “provide assistance in moving from this besieged territory, provide first aid and hygiene products, organise hot meals and many other forms of assistance.”

The Fundly campaign is now defunct and the website does not publicly show the results of closed projects. But based on snapshots from the wayback machine the fundraiser didn’t raise much money - around $1500 in the latest version available. Still, “not a lot” does not equal “zero” which is how much money ACFHCUM claims they received as donations in 2022 and 2023.

Bringing This All Together

The American Charity Fund for Helping Children of Ukraine and Moldova Inc. does not and has never operated like a typical non-profit. At no time in their history were they clearly raising money publicly for the causes that they claim to support or dispersing money as charitable donations. Most of their reported financial activity in 2019 and 2023 involved nearly identical sums moving in and out of the organization in the same year - mostly as round numbers, all towards contractors or expenses.

Also important is the apparent unreported financial activity - both in small dollar donations for Ukrainian children, and sponsoring the most expensive congressional delegation of 2021.

It is entirely possible that there are reasonable explanations for this unusual behavior, but given the opportunity Sam Alaverdov chose not to provide them to me.

Regarding our primary concern, the $85,000 PR contract supporting Vasilie Tarlev, we can also draw some conclusions. ACFHCUM did not just have extra money lying on the shelf and decide to support a politician because Sam Alaverdov “likes” him. Year after year this organization had no income at all and nothing on the balance sheet before suddenly signing a contract representing more than all of their (reported) past income combined.

It’s possible that these answers will be available next spring when ACFHCUM files its 2024 form 990 with the IRS. It is also possible that their past history of very questionable filings means that there won’t be much more information there.

Finally, because closed door meetings with politicians are, by their nature, non-public, we don’t know what Mr. Tarlev is doing with all of this expertise and sponsorship. He has not made any posts about politicians outside Moldova recently except one - a post praising Donald Trump on his re-election.

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Leaked Recordings Connect the FSB to the Stoianoglo Campaign

Yesterday a website called “Lubyanka Leaks” published a series of recordings purporting to be phone calls between Socialist MP Adrian Albu and Yuri Gudilin, a known FSB agent under US sanctions. Gudilin is, at least nominally, a “former” FSB agent turned political consultant focused on Moldova. He was an advisor to Igor Dodon’s 2020 election campaign organizing propaganda from the Moscow based “Troll Factory,” cryptocurrency money laundering schemes for campaign finance and other such dark arts. Since the war started he allegedly attempted to run an operation whereby vandals would break into lots of cars in Chisinau. Then they would blame Ukrainian refugees in order to poison Moldovans against Ukrainians.

Adrian Albu on the other hand is a senior member of the Socialist Party and a top campaign surrogate of Alexandr Stoianoglo. He was Stoianoglo’s proxy at pre-election debates that the candidate did not attend in person.

In the recordings, which are alleged to be from April of this year, they discuss Albu’s travel plans to Moscow, with tickets purchased by Gudilin. Albu is cautious and wants to make sure that he doesn’t stay at any hotels frequented by Moldovans who he is concerned could be Moldovan Security and Information Service (SIS) officers. He says:

“I don’t want to show up at Four Seasons because I don’t want to be noticed by a piece of shit which monitors. Our guys [SIS] are not stupid, trust me on my word. And those faggots that were present in the conference room, there should be a rat among them.”

On his trip to Moscow Albu met with multiple high ranking officials including Nikolai Patrushev, former head of the FSB and known to a be a close, and hawkish, advisor to Putin.

Many of the recordings are focused on how they can better support Ilan Shor. In their calls Gudilin instructs Albu on how they can launder Ilan Shor’s reputation in Moldova. He recognizes how toxic Shor is but notes that “given the level of support he now enjoys here [in Russia]” he will continue to lead the Moldovan effort for the Kremlin. He calls Shor “one big black spot” and suggests that the way to manage this is to make “many many such spots” by painting the current government as dirty. Basically, don’t build Shor up, tear everyone down into the mud with him. The goal was to present the electorate with a situation where…

“It’s just one group of bandits fighting another group of bandits; only that one group points the finger at the other and screams that they are evil.

There’s lots more information about the calls and how top Socialists and Stoianoglo campaign officials are receiving direct instructions from Moscow. Further, it is telling that there is no difference in the Kremlin’s view between the Socialists and Shor - they are all on the same team.

It is important to note that the Socialists claim that these audio files are fake. At the time of writing there has been no independent authentication of the files.

I won’t go further into this here though because you can read it all yourself - the original article reporting on these leaks was written in English. In EU Reporter.

If “EU Reporter” caught your eye it may be because you read my in-depth article tracking English language influence operations in the EU (if not, take a break and read it now - it will help explain what comes next).

An Influence Operation Exposes… an Influence Operation?

So as we’ve written before EU Reporter is not actually a news site. There are no reporters (at least not real ones) and their slogan “independent media for a better debate” is a blatant lie. EU Reporter prints paid articles placed by individuals or PR firms and launders them into the Brussels bubble by making them seem like real news.

Predictably the same article appeared in 2 other websites with the same “business model” - The London Globe and the New York Globe.

So this website was a paid placement and was not written by a journalist. What about the leak?

The website “Lubyanka Leaks” is brand new - registered just 3 days ago on October 28th. The name makes it sound like some kind of established site but really it’s just the one page with the audio files. If you try and navigate to a homepage there is only an administrator login to upload more files to share.

So taken together we have an article written by unknown persons, audio recordings purporting to be intercepts of an FSB handler and Moldovan client and a website set up to distribute the audio information. Why?

Sounds like Spooks…

We can’t rule anything out but it seems highly unlikely that the source of the leaks was in Moldova. If someone had these leaks and wanted them in the press they would simply give them to a local journalist. Hiring a PR company (or similar) to write an article, paying for placement in multiple bogus English language news websites and building a website to host the files would be a hilariously roundabout for someone with ZdG journalist on speed dial.

ZdG, Newsmaker, Agora and others did pick the story up of course. It’s now a huge story in Moldova.

So who would go through the trouble to place a story like this? That’s unclear. What is clear is that someone did. Almost certainly someone outside Moldova. Clearly someone that isn’t a fan of Russia’s meddling in the country’s affairs.

The Irony of course is that for the last year EU Reporter has been part of the operation described in these leaked phone calls. It has run article after article supporting Ilan Shor, condemning the human rights record under Maia Sandu and generally undermining Moldova’s EU path. In short, making more “black spots.”

Just last week the site published an open letter written by Marina Tauber and top Shor party leadership alleging that the EU referendum was falsified. None of these English language articles, planted by PR firms working for Shor or Kremlin linked groups, were designed to target a Moldovan audience. This article seems to have been.

More than anything else the story of this election has been one of external interference and manipulation. It looks like someone else just got in the game.

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While Moldova has been distracted by Romanian and Russian language disinformation and propaganda campaigns coming from the Kremlin, a different kind of campaign has been happening in the West. Since early Spring 2024 a flurry of articles have been placed in English language media outlets in one or more apparent PR campaign(s) managed by Public Relations (PR) and lobbying companies from around the world.

These articles all promote a set of common narratives about Moldova, namely that Moldova is sliding into authoritarian rule, Maia Sandu is a threat to democracy, Moldova attacks free speech and journalism, Moldova has undemocratically banned the Chance (or Shor) parties, etc. One key theme that returns again and again - “Moldova is not ready for the EU” and “Moldova in its current form is a threat to the EU.”

These articles claim various attributions, some are op-ed’s, some are written by supposed journalists, some are directly from PR companies. Untangling who actually writes what gets challenging, a topic we will return to below, but one name comes up again and again - Stanislav Pavlovschi. He is cited either as an author of articles or the subject of them. All promote his new NGO, founded in February of this year, the International Center for the Protection of Human Rights and Democracy (ICPHRD).

Who is Stanislav Pavlovschi?

Stanislav Pavlovschi, aged 69, is a Moldovan lawyer and former judge appointed by Moldova to the European Court of Human Rights (ECtHR) from 2001 to 2008. He later entered politics joining Andrei Nastase’s “Platform Dignity and Truth” (Platform DA) party. From here he was appointed as the Minister of Justice in the Maia Sandu cabinet on June 8, 2019 before resigning only a few weeks later on June 23rd. He stated that his resignation was due to a “constitutional incompatibility1” with serving and that in respect of the constitution he must resign. He subsequently announced on September 16th, 2019 that he was retiring from politics and returning to legal practice.

So Mr. Pavlovschi has had a distinguished career but he is hardly a household name in Moldova. He returned to politics this year in support of Andrei Nastase’s presidential campaign where he plays a senior role among Mr. Nastase’s supporters.

Pavlovschi has appeared prominently alongside Nastase in the campaign including at the campaign launch where he spoke in support of Nastase. He has also endorsed him publicly, an endorsement that is prominently displayed on the candidate’s campaign website.

In addition to re-entering politics to support the presidential candidacy of Andrei Nastase, Mr. Pavlovschi made a sudden and dramatic appearance on the international stage last spring when he founded an NGO called the International Center for the Protection of Human Rights and Democracy (ICPHRD).

Through this organization, and leaning heavily into his credibility as a former judge at the ECtHR, Mr. Pavlovschi has written numerous op-eds and arranged 2 conferences dedicated to the topic of media freedom in Moldova. His conclusions? Moldova has serious problems with media freedoms and much more.

Stanislav Pavlovschi’s Articles

The first step in Mr. Pavlovschi’s new campaign is a series of op-ed articles placed in various papers targeting an EU audience. In a fairly typical piece for Euractiv2 Pavlovschi says that he is writing “Drawing from my experience as a former Minister of Justice in Prime Minister Maia Sandu's administration” to comment on justice reform efforts and corruption in Moldova. He does not mention that this experience consisted of 16 days as minister. Pavlovschi writes about how Moldova suffers from endemic corruption and that:

“Under President Maia Sandu's administration, Moldova has witnessed a systematic erosion of media freedoms, with nearly a dozen opposition media outlets shuttered and independent voices silenced.” .. “Furthermore, the exclusion of opposition candidates from participating in local and parliamentary elections represents a blatant disregard for democratic principles and electoral integrity.”

From this we get a pretty good idea of what he is talking about. Through his articles we find the same themes again and again:

• Maia Sandu has eroded media freedoms / is an authoritarian / is creating a totalitarian system.

• Moldova is not ready for the EU. Any attempt at joining the EU before sorting out Moldova’s internal problems will hurt the country

• Moldova is dangerous for the EU. Accepting Moldova risks a new ‘Hungary’ crisis

Critically, whenever he needs to reach for an example to prove these points he highlights the following:

1. Moldova is banning opposition parties - Chance / Shor

2. Moldova is banning opposition media channels (referring to SIS blocking Russian channels, the government restricting licenses of Russian and Shor owned radio / TV, etc)

Throughout the articles Mr. Pavlovschi professes time and again that he loves the European Union, he wants Moldova to join the European Union… but. There is always a “but.”

What he never addresses is Ilan Shor.

This is telling by itself. He is writing quite a lot about the death of democracy and rise of totalitarianism and citing as his only proof the banning of Russian state TV channels, TV channels owned by Ilan Shor and political parties run by Ilan Shor. Why not mention him?

Stop Media Ban

Another reoccurring theme is crossover between Mr. Pavlovschi’s content and a new NGO called “Stop Media Ban.” The NGO describes itself as follows on its website:

STOP MEDIA BAN (SMB) is an independent non-profit organization committed to combating media repression and upholding the freedom of the press. Established in Moldova following the government’s prohibition of several major TV channels in the country, SMB has since been dedicated to promoting press freedom rights both domestically and globally.

The NGO was founded by “journalist” Alexei Lungu back in May 2023. Lunga went on to become leader of the Chance Party in August 2023 making him one of Ilan Shor’s top surrogates in Moldova. The current director of Stop Media ban is Ludmila Belcencova, a former Communist Party MP and TV journalist with Communist linked channels. In December 2022 she was the General Producer of the TV station “Primul în Moldova” which was later blocked and placed under EU sanctions for spreading Russian propaganda. In practice, Primul was just a Romanian language version of Russia’s state owned Perviy Kanal (Channel One).

The purpose of Stop Media Ban is to launder messages about “declining press freedoms” in Moldova by hiding them amongst broader complaints about press freedoms globally. The organization decries a lack of media freedoms in even Russian proxies and friendly governments such as Serbia, Iran, China, Hungary and Turkey in an attempt to present themselves as global champions of press freedom. At the same time no less than 1/3 articles they produce are about Moldova.

Stop Media Ban quotes Stanislav Pavlovschi in their campaigns and he has cited Stop Media Ban alongside Amnesty International in his articles in support of his arguments against banning the Chance Party.

To be clear, Stop Media Ban is designed to have just enough credibility to fool MEPs and Western decision makers who are not well versed about Moldova - with some success. It is not designed to fool Moldovans who know very well who Alexei Lungu and Ludmila Belcencova represent. It is not credible that Mr. Pavlovschi could mistakenly believe Stop Media Ban to be equivalent to Amnesty International.

Of course, there are further indications that this is not at all a coincidence. Above we cited an article he wrote in Eurativ. As per standard journalistic practice, Euractiv noted that that article was a “paid promotion.” Mr. Pavlovschi paid them to run his opinions. He paid others too, but some sites are not quite as ethical and did not disclose that these were paid placements. This brings us to the murky world of international PR and foreign agents. To sites like EU Reporter.

How Foreign Influence PR Campaigns Work

Most people are aware, at least at some level, about how lobbying works. An interest group will hire a lobbyist to promote their given interest to whatever political actors are relevant. This can involve meetings, writing press releases, helping frame campaigns and the whole gamut of the political dark arts that, while unsavory, are legal.

Public Relations (PR) is a subset of this darks arts whereby a firm manages the image of a client or a campaign. These firms, which charge *huge* amounts of money, will write articles, press releases, organize meetings with leaders and generally manage the public side of whatever effort is underway. When the client is a foreign government, foreign company or foreign individual the United States regulates this under the Foreign Agents Registration Act or FARA.3 The European Union does not have any equivalent of this law and many member states don’t either. Notably, Belgium.

Back in 2021 Politico published a 3 part investigation called Dark news: The murky world of undercover EU lobbying.4 In it they show how websites like EU Reporter, EU Political Report, EU Today and others masquerade as news websites while actually covertly selling article placements to PR firms. These articles are written as if they are news, attributed to journalists (often not real - more below) and positioned online as credible reporting. In reality, they are well funded PR campaigns meant to influence readers. In the case of the 3 sites above the main targets seem to be EU level politicians.

One of the sites most “interested” in carrying Stanislav Pavlovschi’s articles is EU Reporter. In a now deleted youtube video referenced by Politico, EU Reporter advertised its services as "Use EU Reporter to influence." They explained their work as follows:

"Our business model is to offer political parties, businesses, NGOs, industry associations, financial institutions and governments the opportunity to use EU Reporter to influence the European political decision-making process by sponsoring coverage and the placement of positive news stories and editorial comment related to them,"

No articles on EU Reporter state that they are paid. They are often mirrored on other, similarly unscrupulous sites and in each case are attributed to a different journalist.

Placement Clusters

For this purposes of this story I’m choosing to create my own new concept - a PR placement cluster of articles. The idea is simple. If a website, or group of sites previously reported to be pooling articles for PR firms, suddenly have a lot of articles about Moldova we’ll call that a cluster. These sites have no real journalists, no contributors. Before and after our “cluster” of articles these sites will go for years without covering Moldova. These clusters appear, in most cases, to be articles planted by the same actor - likely a PR firm.

EU Reporter Cluster

Since February 2024 EU Reporter has run 25 articles about Moldova. Of them, 2 appear to be straight news by “EU Reporter Correspondent” or “EU Brussels Correspondent.” Both are in fact just copied and pasted European Council Press Releases.5 Of the remaining articles all are clearly outside placements by PR firms pushing a specific agenda. Of those, 7 articles are by or about Ilan Shor’s lawyers and their attempts to lift sanctions against him.6 Six are by or about Stanislav Pavlovschi7. Two are by or about Stop Media Ban.8 One is a hagiography of Victoria Furtuna9, one of Shor’s candidates for president. And 3 more push other Russian talking points against Moldova such as why the country should buy Russian natural gas, etc.

As you can see from the extensive footnotes, some of these articles went on long journeys after being published, with other less than reputable outlets picking them up. EU Reporter also clearly misattributes authorship to itself for articles that originated elsewhere or were written by 3rd parties. In one article about Stanislav Pavlovschi attributed to “EU Reporter Correspondent” we find that the article was originally posted on a site called EIN Presswire and attributed to Robert Naouss.

Robert Naouss leads a boutique PR firm in Dubai named Advocacy Impact LLC. His Co-Founder is Milena Nichisova, a native of Moldova and former employee of the Ministry of Foreign Affairs. In the article attribution he is listed as representing ICPHRD.

This brings us to a second cluster with EIN Presswire and another PR company - “Broken Pot Media Ltd.”

EIN Presswire Cluster

EIN Presswire is a site that allows users to push a press release onto the press wires for the low price of $99 / article. What makes this cluster interesting for us is that they identify who paid for and placed the articles. In this cluster we have 5 articles all placed by the same company, Broken Pot Media Ltd, between March 28th and August 1st of this year.

Of those articles, 2 were about Stanislav Pavlovschi10, 3 were written by Ilan Shor’s lawyers directly11 and 1 was about Victoria Furtuna.12

One of these articles shows you just how some of this reputation laundering works. An article attributed to Stanislav Pavlovschi was placed in EIN Presswire by Broken Pot Media Ltd. This article is written in the 3rd person with Mr. Pavlovschi quoting himself for much of the writing. The Associated Press (AP) picks up the article from EIN Presswire… and Mr. Pavlovschi posts the article back to the main page of the ICPHRD website citing only the AP as the author.

The EIN Presswire / Broken Pot Media Ltd cluster is important because it clearly shows that the same company is promoting both Ilan Shor’s lawyers statements and Stanislav Pavlovschi and the ICPHRD.

The International Policy Digest Cluster

The final cluster that I’ve chosen to highlight in this report is the most fun in some ways. After Politico’s 3 part exposé on EU Reporter, that website made some changes - not to become better but to hide who they were better. They still use fake names for reporters but they stopped using stock images to pretend these were real people. Not so for The International Policy Digest.

On this site we get 5 articles place between March 10th and August 14th of this year. Of these articles 2 have the basic theme of “Moldova is hell,” PAS is corrupt and international partners should save their money and not bother.13 One is written by Stop Media Ban14, one by Stanislav Pavlovschi15 and one is a hagiography of Andrei Nastase16 attributed to a reporter named Gustav Ellison. Mr. Ellison has no profile anywhere else on the internet, and the photo purporting to be Mr. Ellison appears to actually be Krste Demerdjiev - a social media freelancer from Macedonia.

This article is unsubtle, “Năstase is viewed as a dynamic, fearless leader with a hands-on approach.” It makes no mention of his actual electoral prospects. It goes out of its way to attack Maia Sandu and offer up Mr. Nastase as a “credible” alternative.

This same article was also placed on Forbes.ge as “Andrei Năstase: A Voice for Reform in Moldova” noting the author only as Forbes.ge.

Naturally Mr. Nastase liked these articles posting them on X and his campaign website.

This is not the only unusually good press Mr. Nastase has gotten in English language media sources. In July an especially flattering article was published in The Independent similarly promoting the candidate while taking no realistic stock of his electoral chances.

These 3 “Clusters” of articles are only meant as an example of the kind of information being spread by groups promoting Stanislav Pavlovschi, Ilan Shor, Stop Media Ban and others in the English language (less than scrupulous) press. There are many many more examples.

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The Campaign is Not Limited to the Internet

So far we’ve focused on what appears to be a coordinated, online influence campaign promoting an anti-PAS, anti-Sandu and pro-Shor set of messages. At the same time there is a parallel real world campaign pushing the same sets of ideas to decision makers in the United States and Europe.

The 2024 Rule of Law Symposium

On April 17th and 18th the ICPHRD officially launched with a symposium held in New York City dedicated to “focusing on contemporary rule of law challenges in the Republic of Moldova.”

In a press release announcing the symposium the ICPHRD stated:

The symposium will feature esteemed participants including Carsten Zatschler, Adjunct Professor at University College Dublin and expert in EU law, and Justin S. Weddle, a US-based criminal lawyer with experience in Eastern European legal systems. Matthew Hoke, a former FBI agent, will also contribute insights into cross-border financial crimes. Additional invitees include Barnes & Thornburg Partner Scott Hulsey, as well as Kibler Fowler & Cave’s Nathan Park, who will in turn provide diverse perspectives on Moldova’s legal and political landscape.

This event, which Stanislav Pavlovschi called a “significant step forward in our ongoing commitment to justice, democracy, and human rights” had some substantial connections to Ilan Shor.

Firstly, Carsten Zatschler is a member of Ilan Shor’s 4 person legal team challenging EU sanctions against Shor.

Shor had posted a subtitled video of the event on his Telegram channel which is now unavailable due to Telegram’s removal of Shor’s network.

Justin S. Weddle17 and Matthew Hoke conducted an “independent review” of Moldova’s prosecution of Ilan Shor which they presented and was written about in EU Reporter after the event. In it, they conclude that

“neither the Moldovan Court of Appeals decision nor its reasoning, should be treated as a reliable basis for U.S. institutions to reach conclusions about Shor and his conduct.”

In essence, their analysis was that Moldova’s prosecution of Shor was flawed end to end highlighting both the failures of the Moldovan justice system and the need to reconsider sanctions against Mr. Shor.

A “Landmark” Conference in Chisinau

On June 25th the ICPHRD hosted a second conference titled “Freedom of Speech: A Cornerstone of Democratic Societies” in Chisinau Moldova. Stanislav Pavlovschi and his son in law Leonid Tverdun hosted the event for the ICPHRD and presentations were given by a group of international experts including:

• Mitchell Barak - An “Israeli-American public opinion expert” who runs a strategic communications firm based in Israel. He was a former aide to Bibi Netanyahu and is a regular contributor to the BBC, Al Jazeera and others.

• Zeynep Ardıç - A member of Faculty of Law at Istanbul Medeniyet University.

• John Fund - A senior editor of The American Spectator, and reporter for The National Review Online. Fund has a long history of op-ed journalism in the US.

• Tanya Beckett - A British TV and radio journalist, currently a presenter at the BBC world service.

• Ivor Gaber - British academic and journalist, professor of political journalism at University of Sussex. A member of UNESCO’s intergovernmental Council of the International Programme for the Development of Communication (IPDC) representing the UK government.

• Conor Powell - A veteran TV correspondent reporting for Fox and other outlets from various conflict zones. More recently a podcast host and producer.

• Daniel J. Mitchell - A libertarian economist and commentator and a former senior fellow at CATO institute.

• Daniel Pomerantz - CEO of Reality Check, a 501c3 non-profit focused on public research to reduce polarization.

• Walid Harfush - Vice President of Euronews for Central and Eastern Europe.

There’s a decent chance that many readers will recognize at least one name on this list. For a conference in Chisinau this is a pretty remarkable collection of media voices from around the US and Europe. This conference was not promoted in Moldova and received next to zero media coverage here. Moldovans were not the audience.

Following the conference the ICPHRD put out a press release with selected quotes from various participants. They appear to be cherry picked and taken out of any context in order to reinforce same themes present in Mr. Pavlovschi’s articles.

“I do not think the shutting down of media outlets is in any way justified, and governments should not make up excuses to ban media outlets that oppose them.” - John Fund

“if you do not have free media, you cannot expose corruption and hold authorities accountable.” - Zeynep Ardic

“a journalist should never have to be afraid of the power of their government” - Daniel Pomerantz

“according to the World Bank’s governance indicators, things have not improved in Moldova, referring to the connection between quality of governance and how well the economy improves” … “all the scores are weak by European standards” .. “Things are not getting better in terms of quality of institutions either” - Dan Mitchell

I reached out to various speakers asking them to comment on the conference and how it was organized. Conor Powell responded to my questions explaining that the conference itself was small, only around 10 people attending other than the speakers themselves.

He stated that:

"There was definitely nothing pro-Russian about the event or the speakers. That was something I was looking out for. In fact all of the speakers, in both private and public comments, were critics of Putin.” […]

"I came away thinking that Moldova, while it may have some political issues, is actually light years ahead of most countries around the world in terms of corruption and free speech."

As to the content of the debate he stated:

"There was a real debate about freedom of speech and how far it should be allowed in a country like Moldova. If I remember correctly, everyone agreed freedom of speech is key to democratic reforms and a flourishing democracy."

When asked whether or not this was an academic and high level conversation, or a discussion of the actual situation in Moldova right now he replied:

"generally the conversation was high level and in the abstract. It was more best practices from around the world and what Moldova could learn from European countries and the US. Very little conversation focused on Moldova specifically." […]

Prompted about Ilan Shor specifically he said:

"I don't remember any mention of Ilan Shor at all."18

Lobbyists and Meetings in the United States

In addition to conferences, there is a parallel non-public campaign to meet with decision makers and think tanks in the United States. Multiple sources who asked to remain anonymous confirmed to me that Stanislav Pavlovschi, Andrei Nastase and Vasilie Tarlev have all attempted to set up meetings with think tanks and similar institutions in the United States via contracted PR firms in the last few months.

Andrei Nastase made travel plans to the US for these meetings before abruptly canceling his trip. Vasilie Tarlev similarly canceled his trip last minute. It is unclear if Stanislav Pavlovschi actually had any meetings in the US.

I’m currently not able to say which PR firms are or were representing these men and organizing their trips. There are no active FARA registrations for firms representing Moldovan clients. When Nastase visited the Republican National Convention (RNC), a story he has not explained in detail, he was photographed at a reception hosted by BGR Group, a high powered PR and Lobbying firm, but there is no evidence at this time that this is the firm he is working with.

The story of the US visits remains only partial at this time, as does any equivalent stories of high level meetings in the UK or EU. I hope to follow this story up with additional reporting on this topic later.

Bringing it all Together

Through many hours of online research and dozens of conversations I have found no evidence of any lobbying or PR effort in the west by any Moldovans other than Stanislav Pavlovschi, Andrei Nastase and Ilan Shor.

At the same time, we cannot say definitively that the efforts of these three men are linked. Yes, they all hired PR firms, yes they were sometimes the exact same firm at the exact same time, but all the smoke in the world doesn’t quite prove a fire (but it does make a strong case for better public transparency laws in the EU).

What is known?

Stanislav Pavlovschi has conducted a far reaching online and offline campaign focused on discrediting Moldova’s EU aspirations and advocating for the Chance Party and Russian / Shor linked TV channels. At no time does he discuss who Ilan Shor is, what specific interference is happening or why the government made the choices they did. In this campaign he has promoted Shor-linked Stop Media Ban and collaborated with at least one of Ilan Shor’s lawyers.

Mr. Pavlovschi is closely tied to Andrei Nastase and has a prominent role in his campaign. Mr. Nastase promotes Mr. Pavlovschi via his media sites and appears next to him at campaign events.

Mr. Pavlovschi has worked to cultivate the image of a pro-EU jurist and activist in order to gain access to forums where he then disparages Moldova’s prospects for joining the EU. His Chisinau conference did not do so when the attendees were in the room, but the public readout was selected to promote the same narratives that Mr. Pavlovschi pushes through paid articles. The other outcome of this conference is photos of him with prominent international journalists. This is likely to help him launder his image as a credible pro-EU figure in Moldova - someone you might make time for if a high powered PR company calls.

Money. All of this costs a lot of it. The ICPHRD has not made public any of its sources of funding - highly usual for a Moldovan NGO. Because the NGO is so new there are also no public financial reports available. I called the ICPHRD to ask about their funding sources and discovered that their phone number, which has a New York City area code, is disconnected. Some googling found that the number had previously been registered with a daycare center. The ICPHRD has not replied to my emails at the time of writing.

This story is hardly over but already long and complex. As new information becomes available I will write followup articles on this foreign lobbying / public opinion campaign.

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