The $45,000 Discrepancy: Inside a Failed Moldovan Lobby Push in Washington
Investigations Update: June 12, 2025
New filings related to Vasile Tarlev’s abortive 2024 lobbying efforts in Washington DC present major inconsistencies and call into question who paid for his outreach to American politicians, media and institutions.
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:
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.
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.
Yes, they refer to themselves by this clunky acronym
For more on FARA, read Casey Michel’s excellent new book Foreign Agents on how it works, how it doesn’t and how it shapes US politics.
So why did I miss the filing in the May 7th article (which has since been updated)? There are a few possibilities. Firstly, while the Department of Justice marked the document as received on April 30th, we don’t specifically know when they uploaded it to their online database. Secondly, when looking for these filings I was focused on a search section dedicated to the relationship with Mr. Tarlev - this part of the database still marks the contract as “active” to this day and clearly hasn’t been updated since the original filing. The new supplemental filing covers all the work Qorvis did in this period, not only Mr. Tarlev, and its possible that it was online on May 7th and I missed it because the section related to him directly was not updated.
Note: there is ambiguity as to the actual tax status of this organization. We covered it in the original investigation.
Moldova’s national average salary in 2024 was around 14,000 lei / month. This means that any expenses greater than ~$8000 would have to be reported.
It’s worth noting that the Qorvis filing is riddle with typos and misspellings - including misspelling the name of a US Congressman and one of their own employees.
ACFHCUM lists 3 officers of the organization who each (rather improbably) are reported to spend 20 hours / month organizing the “nothing” that the NGO does. Nina Morozova (President), Olga Morozova (Director) and Sam Alaverdov (Director). I reached Sam Alaverdov for comment on the previous investigation and he appears frequently on contracts and reports for the organization. I have not been able to identify Nina and Olga Morozova from any information that appears online and I was able to rule out *an* Olga Morozova who was previously reported to have been involved with ACFHCUM by a far-right American website associated with Infowars (for that story see footnote 5 of the original investigation).