On June 7, 2022, an affidavit inadvertently made public details of an investigation into retired General John R. Allen for allegedly failing to register under the Foreign Agent Registration Act (FARA) after acting as an agent of Qatar’s government. Court documents reveal that in April 2022, federal prosecutors in the Central District of California applied for a search warrant against General Allen, a four-star Marine general who led U.S. and NATO forces in Afghanistan, to search his electronic communications for evidence regarding an alleged campaign to influence U.S. officials on behalf of Qatar.

According to the search warrant application, provided here, General Allen in 2017 allegedly joined an undisclosed campaign to promote Qatari interests to Executive Branch officials and members of Congress. He worked alongside Richard Olson, a former U.S. ambassador to the United Arab Emirates and Pakistan, and Imaad Zuberi, a business executive with ties to the middle east. When General Allen allegedly began his work, Qatar was suffering from diplomatic fallout surrounding allegations that it supported terrorist organizations like Hamas, and Doha was seeking political contacts in Washington to manage the crisis. As a part of the search warrant application against General Allen, the government’s affidavit alleges that:

• General Allen corresponded with, met with, and successfully lobbied U.S. officials to release public statements sought by Qatar. For example, in June 2017, General Allen allegedly contacted National Security Adviser H.R. McMaster and other National Security Council personnel to relay Qatar’s request for help in responding to its diplomatic crisis. General Allen allegedly misrepresented the nature of his work by failing to mention that he had been enlisted to work on behalf of Qatar or that he had agreed to receive payment for his work.
• General Allen attended meetings, organized by his colleague Zuberi, with members of Congress to convey the Qatari government’s desire to resolve the diplomatic crisis. In an interview cited in the government’s affidavit, General Allen acknowledged meeting with multiple members of Congress, including senior members of the House Foreign Affairs Committee, to convey Qatar’s position.
• General Allen allegedly sought compensation for his advocacy work for Qatar, which he described as “speaking engagement” fees of $20,000, to be facilitated by Zuberi. Financial records confirmed that Zuberi paid for General Allen’s travel expenses to and from Doha. The government’s affidavit did not confirm whether Zuberi eventually compensated retired General Allen for his work.

Notably, a court sentenced Zuberi to 12 years imprisonment, including the statutory maximum of five years for a FARA charge, after Zuberi in 2019 pleaded guilty to a FARA offense and in 2020 pleaded guilty to obstruction of justice, among other offenses. In January 2022, Olson pleaded guilty to advising a foreign government with the intent to influence U.S. officers in violation of a prohibition on such activity within a year after leaving diplomatic service. Olson was not charged under FARA.

FARA aims to promote transparency by disclosing foreign governments’ efforts to influence U.S. policy and the U.S. public. FARA requires agents of foreign principals who engage in covered activities, like political advocacy on behalf of a foreign government, to report these activities to the U.S. government. Reportable activity under FARA is broad and includes engaging in political activity or activities designed to influence the U.S. government or public, acting as a public relations counsel or publicity agent, fundraising or disbursing funds, or lobbying Congress or the Executive Branch on behalf of a foreign principal. Agency under the statute is also broad and requires neither payments from nor a contract with a foreign principal.

The federal investigation into General Allen’s involvement in the Qatari advocacy campaign is one in a string of recent Department of Justice (DOJ) actions aimed at ensuring that advocacy and lobbying efforts in the United States on behalf of foreign interests are reported. In addition to the actions involving Zuberi and Olson, in May, DOJ filed an indictment against Thomas J. Barrack, Jr., an informal adviser to former President Donald Trump, for failing to register as an agent of a foreign government under 18 U.S.C. § 951 after working on behalf of the United Arab Emirates. In the same month, the DOJ initiated an affirmative civil enforcement lawsuit under FARA for the first time in 30 years when it sued real estate developer Stephen A. Wynn to compel him to register under FARA.