Amend, Reverse, Repeat: Qorvis Scrambles to Fix FARA Filings After Moldova Matters Investigation
Investigations Update: July 15, 2025
Washington DC based PR / lobbying firm Qorvis has filed multiple, sometimes contradictory, FARA amendments, apparently in response to Moldova Matters’ reporting. With these new filings we can now report who paid Qorvis $45,000 to represent Vasile Tarlev in Washington DC.
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 -
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:
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.
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.
$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.
Yes, they refer to themselves by this clunky acronym
full legal name Semen George Alaverdov
A problem that may have been a harbinger of things to come as he is now reportedly banned from entering the Schengen area as well.
Great synopsis and a very interesting look at the money laundering going on. Job well done. I will continue to follow this intriguing story. Learned a lot here.