The final two months of 2022 saw seventeen new FARA filings involving principals from countries as varied as the Bahamas, Niger, Spain, and Saudi Arabia. Several of the filings are quite lucrative, including one from the Sudanese company, Barkal LTD, which hired RB Crowe LLC for $90,000 per quarter (p.12). But in this edition of the FARA Files, we will examine three filings in particular. The first involves a Saudi-based principal seeking advice on advancing sustainable travel; the second (and most expensive) was filed by the government of Montenegro regarding, among other things, Russia’s invasion of Ukraine; and the third was filed on behalf of the Bahamian government over the fallout of the collapse of the cryptocurrency firm FTX.
Filing 7206 | Registration Statement | Exhibit AB | Short Form
In late December of 2022, Isabel Hill filed on behalf of her client, Kafa’at Company. Kafa’at is a Saudi “human resources solutions” firm seeking to “[achieve] the Saudi Arabia vision for the year 2030.” Kafa’at is ultimately owned by the Saudi government. For a fee of over $160,000, Hill is expected to “advise” Kafa’at on how to work with the U.S. government in “advancing sustainability in the travel and tourism sector.” The Saudi Vision 2030 is the sweeping pet-project of Crown Prince Mohammed bin Salman that envisions the Arab kingdom as a diversified, dynamic, and modern economy.
Vision 2030 is hardly a unique proposition for Saudi Arabia’s neck of the woods, as pointed out by the Washington Institute, which notes that, “the UAE has its ‘Vision 2021,’ Qatar a ‘National Vision 2030,’ Kuwait a ‘Vision 2035,’ and Oman a ‘Vision 2040.’” The Institute also highlights the fraught nature of the Vision, as it is currently centered around gigantic projects that are as risky as they could be profitable.
Part of what makes Hill’s work for Kafa’at so curious is that the work revolves around tourism, an industry that the Arab Kingdom has little experience in. Countries that have thriving tourism industries typically have native attractions that companies and investors can draw on, such as cultural monuments or natural landscapes. The Kingdom does have experience managing the famous Hajj, the annual pilgrimage to Mecca that all Muslims are expected to make at least once in life, but it is unclear how the country plans to incorporate the Hajj into its push for international tourism.
Another point of curiosity with Kafa’at’s filing is that they note their efforts are tied to the “transition to net zero” (p.2). The Saudi economy is, perhaps more famously than any other, almost entirely dependent on fossil fuels, and is the primary source of the government’s revenue. One of the main sources of skepticism around Vision 2030 centers on the immense challenge to pivot from an entirely fossil-fuel dependent economy to one that has achieved net-zero status. Not only is it materially difficult, but it could also disrupt the delicate balance of the Kingdom’s social contract.
Also, of note in this filing is Kafa’at’s decision to hire Ms. Hill. Part of her directive is to meet with U.S. government officials, and Kafa’at chose a foreign agent who has donated heavily to members of the Democratic Party, over $3,300 in the 2022 election cycle alone (p.10-11). Although the Democrats narrowly lost the House of Representatives in 2022 Midterm Elections, they still maintain the bulk of control over the federal government, particularly the White House.
Filing 7209 | Registration Statement | Exhibit AB | Short Form
Montenegro is a small Balkan country on the coast of the Adriatic Sea, and it was formerly part of the former Yugoslavia. The nation is also the newest member of NATO, joining the alliance during the Trump Administration. The dynamics of Balkan geopolitics is such that Montenegro, despite its small economic footprint, often finds itself in the crosshairs of great power politics, especially as it regards Russia.
For $35,000 a month (p.13), the Government of Montenegro hired Bipartizan Solutions (B.S.) as part of a multi-pronged effort to educate the U.S. government and media about the country and issues important to the people and government of Montenegro. The relationship between the government and B.S. began in September of 2022, when Mordechai Barak assisted Montenegrin Prime Minister Dritan Abazovic during his visit to New York City and Washington, D.C. by organizing meetings with key international bodies. Following the Prime Minister’s visit, Barak created B.S. and was quickly hired by Abazovic’s administration (p.12).
Russia’s war on Ukraine has raised some alarm in Montenegro, although under the specter of Serbian aggression towards Kosovo, rather than Russian efforts. Serbia has never recognized Kosovo’s independence, and despite the international peacekeepers along their border, tensions do fluctuate – often in response to wider world events. Montenegrin officials may fear that ethnic divisions could reignite conflict as part of a domino-effect from Russia’s invasion.
At the time of this writing, in the midst of a tense standoff along the Kosovo-Serbia border, diplomats from a range of nations, including the United States, are trying to calm both sides. This is precisely the scenario that Montenegro hired Barak to clue the Americans in on, so as to not get lost in the geopolitical shuffle.
Filing 7210 | Registration Statement | Exhibit AB | Exhibit C
The collapse of the crypto-exchange firm FTX Trading rocked more than the world of crypto-bros and the tech sector. The Bahamas staked its reputation on becoming a hub of the crypto sector, in an attempt to diversify its economy beyond tourism and traditional banking services. Since the FTX fiasco, however, the government has been in damage control, and as part of those efforts, Brown Rudnick LLP has been the firm-of-choice for the Bahamas, according to the company’s FARA filing.
Following Hurricane Dorian’s destructive visit to the country in 2019, the government figured that there was no better time to look forward and passed the Digital Assets and Registered Exchanges Act, making the Bahamas one of the first countries to pass crypto-centric regulations for companies. Turning this new leaf was supposed to allow the small island country a chance at financial success beyond the infamously risky tourism sector, ravaged by the pandemic as much as it was by Hurricane Dorian.
In hindsight, the Bahamas may have jumped the gun, favoring a quick roll-out over deliberate due-diligence. The collapse of FTX and the arrest of its founder, Sam Bankman-Fried, who was extradited from the Bahamas to the United States, has also cost some Bahamian citizens dearly. Bishop Lawrence Rolle, a major preacher and public figure in the island country, saw his ministry receive a generous donation of $50,000 from FTX, but the firm’s collapse made for a bitter pill to swallow for Rolle.
The future of the ruling government in Nassau is also up in the air. Prime Minister Philp Davis, according to the Associated Press, hitched his political capital tightly to FTX and the crypto push, even partaking in the company’s groundbreaking ceremony for its new headquarters. Despite this, it is unclear to what extent voters in the Bahamas will hold him or his party responsible for the debacle. In a show of resolve, Davis even said in a visit to Washington, D.C. that “our regulatory regime in respect to this space is probably more modern” to the American regulations.
Check back soon for another edition of the FARA Files.
