Investigations Update: How did Vasile Tarlev's American Lobbying Effort Go?
We don't know - and that's a problem.
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 If they close the contract they need to file a supplemental statement indicating that the contract is no longer active.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:
Qorvis failed to file the documents
Qorvis did file, but the website had not been updated yet
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:
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.
The GEC was a department within the State Department focused on fighting foreign propaganda campaigns. It has been dismantled and the Trump administration is beginning a witch hunt of sorts to malign anyone who was involved in it.