TOPLINE: Over the course of almost a year, Rudy Giuliani, a private citizen serving as a personal lawyer to Donald Trump, allegedly pushed the Ukrainian government to launch an investigation into one of Trump’s most prominent potential political opponents and pursued a conspiracy theory about work done by Trump’s convicted former campaign manager Paul Manafort. These efforts are detailed in a partially-redacted whistleblower complaint that was released to the public on September 26, 2019. Giuliani has called the complaint “total nonsense” and denied all wrongdoing.

• Giuliani Line of Effort 1: This alleged effort, solely targeted towards Joe Biden, focuses on a false claim from Giuliani that Biden acted improperly in 2016 when calling for Ukraine to remove the corrupt then-prosecutor general Viktor Shokin. Giuliani’s claims wholly ignore the relevant timeline and the realities of anti-corruption efforts in Ukraine at the time. Instead, he attempted to create an aura of wrongdoing that is not substantiated by fact.
  • In light of the whistleblower’s complaint, it appears that in urging this bogus investigation, Giuliani, with Trump’s blessing, could have been asking a foreign power to interfere in the upcoming election by misrepresenting – or potentially even manufacturing – information on a major political opponent.
• Giuliani Line of Effort 2: Giuliani also reportedly pushed for an investigation into a conspiracy theory that payments made from a Ukrainian political party to Paul Manafort were “part of a plot to wreck Mr. Trump’s candidacy.”

The Players:

• President Trump: In a July 25, 2019 call with Ukrainian President Volodymyr Zelensky, Trump asked Zelensky to cooperate with Giuliani and Attorney General Barr on the investigations.
• Volodymyr Zelensky: Zelensky was elected as President of Ukraine in April 2019, replacing Petro Poroshenko.
• Rudy Giuliani: Giuliani is President Trump’s loyal personal attorney. He is not a government official. Giuliani has reportedly spent the better part of this year communicating with high-ranking Ukrainian prosecutors in an attempt to get Ukraine to open these two investigations (Giuliani has claimed that the State Department requested he contact Ukrainian officials, and has denied wrongdoing).
• Viktor Shokin: Shokin was a Ukrainian prosecutor general who was removed from his post in March 2016 and replaced by Yuriy Lutsenko. Before he was removed, Shokin was heavily criticized by the U.S. and western leaders over allegations of corruption, which he denied.
• Mykola Zlochevsky: Zlochevsky is a Ukrainian oligarch who previously served under the notoriously corrupt president Viktor Yanukovych. Zlochevsky left Ukraine in 2014, and was investigated in Ukraine and the U.K. for allegations that included money laundering. Zlochevsky was never charged with anything and has strongly denied all wrongdoing.
• Burisma Holdings: Burisma is a natural gas company owned by Zlochevsky. Burisma was being investigated as one of Zlochevsky’s businesses, although it denied all allegations of wrongdoing.
• Yuriy Lutsenko: Lutsenko, who took over for Shokin as prosecutor general in early 2016, closed the cases against Zlochevsky and Burisma within ten months of taking office. He reopened an investigation into Burisma in March 2019. In late August 2019, Lutsenko was removed from his post.
• Joe Biden: In 2016, as part of a western effort to crack down on corruption in Ukraine, then-Vice President Joe Biden, on behalf of the U.S. government, threatened to withhold a $1 billion loan guarantee unless Ukraine made certain anti-corruption reforms, including removing Shokin from his post.
• Hunter Biden: Joe Biden’s son, Hunter Biden, joined the board of directors of Burisma in May 2014 and left the board in April 2019. Joe Biden has denied that any of his actions had anything to do with Burisma and there is no evidence to suggest otherwise. There was no investigation of Hunter Biden in Ukraine.
• Lev Parnas and Igor Fruman: Parnas and Fruman are Soviet-born U.S. citizens who, since late 2018, have reportedly been active in assisting Giuliani set up meetings with current and former Ukrainian officials. In a failed effort to get Giuliani a meeting with Zelensky, Parnas and Fruman reportedly met with Ukrainian businessman Igor Kolomoisky (Kolomoisky confirmed this meeting), a Zelensky backer who left Ukraine after being accused of a variety of crimes including money laundering (all of which he strongly denies). Parnas has denied that he and Fruman did anything wrong and claimed Ukrainian officials initiated communications. Fruman and Giuliani did not comment on this story.
• Secretary of State Mike Pompeo: Trump has stated that he instructed Pompeo to not release $250 million of military aid to Ukraine, and House Democrats have demanded that Pompeo turn over any documents related to Trump and Giuliani’s efforts in Ukraine.
• Vice President Mike Pence: Trump also instructed Pence to withhold the funds from Ukraine. After meeting with Zelensky in September, Pence publicly stated that the two men had “discussed America’s support for Ukraine and the upcoming decision the President will make on the latest tranche of financial support in great detail.” The whistleblower complaint does not implicate Pence in any wrongdoing.
• Attorney General Bill Barr: In Trump’s call with Zelensky, he instructed the Ukrainian president to work with Barr on investigating Biden. Trump stated, “I am also going to have Attorney General Barr call and we will get to the bottom of it.” Barr also may have been involved with the initial attempt to withhold the full whistleblower complaint from Congress, as the Justice Department’s Office of Legal Counsel initially tried to withhold it. Barr denies being asked to investigate Biden.

The Meetings:

Giuliani, who was not a government official (the acting DNI was unable to even say if he had a security clearance), reportedly had eight meetings with Ukrainian officials:

• Late 2018: Giuliani and Shokin reportedly held a “Skype meeting” where Shokin informed Giuliani about the investigation into Burisma. The meeting was allegedly set up by Parnas and Fruman.
• January 2019: Lutsenko traveled to New York and allegedly “met for hours” with Giuliani.
• February 2019: Giuliani and Parnas met with Lutsenko in Warsaw.
• Unknown: According to Lutsenko, he and Giuliani met a third time “in Europe,” although it is unclear when or where this meeting took place. Giuliani has not commented on the meeting.
• May 2019: Giuliani met with Ukraine’s Special Anticorruption Prosecutor, Nazar Kholodnytsky (reportedly a Lutsenko ally) in Paris.
• May 2019: During this time Giuliani also allegedly met with a former Ukrainian diplomat named Andriy Telizhenko, also reportedly a Lutsenko ally.
• July 31, 2019: Giuliani met with Kiev Mayor Vitali Klitschko in New York.
• Late July 2019: Several days later, Giuliani went to Spain to meet with Zelensky aide Andriy Yermak. He “strongly urged” Yermak to investigate ties between the Biden family and Ukraine.

It has also been reported that Giuliani planned to go to Ukraine in May 2019, where he was allegedly going to try to meet with Zelensky and ask him to investigate the Biden family. Parnas had reportedly helped him arrange the trip. Giuliani ultimately canceled the trip after criticism that the trip would be an explicit request “that a foreign state interfere in the 2020 election.” Giuliani blamed Democrats for the cancellation.

Giuliani also had numerous other contacts with Ukrainian officials. On unknown dates, Giuliani reportedly held phone calls with Shokin and Lutsenko. The whistleblower complaint alleges that he also “privately reached out to a variety of other Zelensky advisers, including Chief of Staff Andriy Bohdan and Acting Chairman of the Security Service of Ukraine Ivan Bakanov.” The topics of these alleged conversations are not public.

The Bargaining Chip:

• This past summer, Trump withheld $250 million of military aid to Ukraine—in a move that now appears may have been using U.S. taxpayer dollars as a bargaining chip to force a foreign country to do what Trump wanted. The aid was going to Ukraine to help the country fight back against Russia.
• On July 18, 2019, the Office of Management and Budget (OMB) told the State Department and the DOD that the aid was being withheld because of “interagency processes” but did not provide additional details.
• The aid was finally released in September 2019, just before news of the whistleblower complaint broke.

The Trump Calls:

July 2019: On July 25, 2019, Trump held a phone call with Zelensky. This call came just seven days after the Trump administration had decided to withhold aid to Ukraine. In this call, according to a partial transcript released by the White House, Trump pointedly referenced the U.S. aid and then noted that the relationship between the two countries may not be “reciprocal.” Trump also explicitly asked Zelensky to work with Giuliani and Attorney General Barr to investigate Biden, offering a foreign country the resources of the U.S. Justice Department to investigate a potential 2020 opponent.

• “I will say that we do a lot for Ukraine. We spend a lot of effort and a lot of time. […] the United States has been very very good to Ukraine. I wouldn’t say that it’s reciprocal necessarily because things are happening that are not good but the United States has been very very good to Ukraine.”
• “Mr. Giuliani is a highly respected man. […] I will ask him to call you along with the Attorney General. Rudy very much knows what’s happening and he is a very capable guy. If you could speak to him that would be great. […] There’s a lot of talk about Biden’s son, that Biden stopped the prosecution and a lot of people want to find out about that so whatever you can do with the Attorney General would be great. Biden went around bragging that he stopped the prosecution so if you can look into it… It sounds horrible to me. […] I will have Mr. Giuliani give you a call and I am also going to have Attorney General Barr call and we will get to the bottom of it. I’m sure you will figure it out.”

April 2019: Trump and Zelensky held a previous call on April 21, 2019, when Trump called Zelensky to congratulate him on winning the election. The White House did not provide a public readout of this call, although Trump has suggested releasing this transcript as well. House Democrats are reportedly investigating this first call between Trump and Zelensky.