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Exhibit 825

Letter, DOJ NSD Counterintelligence and Export Control Section to Caplin & Drysdale re Podesta Group, Inc. and the European Centre for a Modern Ukraine

Exhibit 825 ยท Agency letter

Letter, DOJ NSD Counterintelligence and Export Control Section to Caplin & Drysdale re Podesta Group, Inc. and the European Centre for a Modern Ukraine

we have determined that Podesta has an obligation to register under FARA.

Determines that the Podesta Group has an obligation to register under FARA for political activities in the United States for the European Centre for a Modern Ukraine, based on its engagement of 18 April 2012. Finds the Podesta Group sent strategic communications to, and arranged meetings with, U.S. officials, media and business leaders. The letter does not state who funded the Centre.

Source
U.S. Department of Justice, National Security Division
Date
31 March 2017
Quoted from
p. 1
Grade
Primary record
Document
https://www.justice.gov/nsd-fara/page/file/1282081/dl
Accessed
2026-11-09
Cited by
Findings citing this exhibit

Cited by

Finding POL-6.6
Primary record The September 2018 Manafort superseding information charges that from at least 2006 to 2015 Manafort conspired with Richard Gates, Konstantin Kilimnik and others to act as unregistered agents of Ukraine, including by arranging payment of over $2 million from offshore accounts to two unnamed Washington lobbying firms, which the information does not identify. On 31 March 2017 DOJ's FARA unit told the Podesta Group and Mercury Public Affairs in separate letters that each had an obligation to register for political activities for the European Centre for a Modern Ukraine.
Finding POL-6.19
Primary record The Podesta Group's FARA registration (no. 5926) was dated 1 April 2009 and terminated on 31 December 2017, with 33 foreign principals on the registration record. The firm reported $24.04 million in Lobbying Disclosure Act income for 2016 and $18.13 million for 2017.