The frontrunner for the Ukrainian presidency, Yulia Tymoshenko, is wasting no time getting ready for what she expects will soon be her new job.

“The presidential election is approaching, and it would be irrational for a newly elected president to use up their precious work hours on building bridges and establishing contacts when it can be done now,” she wrote on her Facebook page on Dec. 4 as she started her visit to Washington, D.C. – her second trip to the United States in 2018.

Ex-Prime Minister Tymoshenko, a veteran Ukrainian politician and the leader of Batkivshchyna party that holds 20 seats in the parliament, has denied hiring any lobbyists in the United States.

But documents filed with the United States Justice Department under the Foreign Agents Registration Act (FARA) show that she has two U.S. agents acting in support of her, hired by what appears to be a shell company whose real owners and sources of funding are concealed. The Kyiv Post has confirmed that at least one of her meetings in Washington last week was arranged by one of those agents.


The Kyiv Post repeatedly tried to reach Tymoshenko for comment, but the ex-prime minister wasn’t available to comment for this story by the time of publication, according to her spokeswoman Natalia Lysova, who cited the politician’s busy schedule.

Daria Kaleniuk, the head of the Kyiv-based Anti-Corruption Action Center, said that according to U.S. legislation, Tymoshenko had to register as a foreign principal if she had hired a lobbying firm. Otherwise, the agents’ services – worth of hundreds of thousands of dollars paid by a third party – would be considered a high-value gift, which Tymoshenko as a lawmaker had no right to accept.


In June, an obscure Maryland-registered company, ITBC LLC, owned by a low-profile Ukrainian-American man called Sergei Krasnitski, hired The Livingston Group, a government relations firm founded by former Louisiana congressman Robert “Bob” Livingston, and a media relations executive named Naomi Decter Munson.


Altogether, their services cost $780,000 a year. That’s more than Tymoshenko has declared owning and much more than she as a lawmaker can legally accept as a gift.

The presidential election campaign officially kicks off on Dec. 31 when any registered candidate must establish an election fund and may receive donations from individuals and legal entities to finance their campaigning. Until then, a politician’s spending on lobbying and advertising should be posted in their party’s financial statements. But Tymoshenko’s Batkivshchyna party has not reported any foreign spending this year.

Moreover, Tymoshenko’s 2017 declaration of assets showed she had earned some $20,000 last year, almost half of it her lawmaker’s salary. In addition, she declared over $32,200 in savings, but no property or business. Her husband, Oleksandr, declared an income of $120,000 from two of his companies and over $620,000 in cash.

Finally, Ukrainian anti-corruption law allows lawmakers to receive gifts with a total value of no more than Hr 3,400 ($121) in one year.

“We’re talking about such wrongdoings as lying on one’s declaration of assets, if Tymoshenko is paying for (the lobbying) herself, or illegal enrichment, if someone else is buying the lobbying services for her,” said Kaleniuk.



The mystery sponsor ITBC, or as it also appears in FARA documents – Innovative Technology & Business Consulting – bears all signs of a shell company. It was incorporated in Maryland in May, some six weeks prior to inking a contract with The Livingston Group with a two-month payment of $100,000. Its address in Pikesville is an office for rent that houses several other LLCs and law firms, the U.S.-based Center for Responsive Politics reported.

ITBC’s owner, a Ukrainian-born resident of Maryland named Sergei Krasnitski, is a 46-year-old native of Dnipro, an industrial city 500 kilometers south of Kyiv and coincidentally a hometown of Yulia Tymoshenko. Krasnitski works as a web developer at a Maryland company called CareFirst Blue Cross Blue Shield, which sells health insurance plans.

When a Kyiv Post reporter called his office, Krasnitski only said in Russian “I don’t know what I can tell you,” before hanging up.

Kaleniuk of the Anti-Corruption Action Center says that the fact that a small firm transfers so much money so soon after establishment is a red flag for money laundering.

Another interesting fact is that ITBC appeared as a legal entity on May 7, four days before another obscure U.S. firm purportedly working in the interests of Tymoshenko rescinded an agreement with a lobbying firm Avenue Strategies, run by U.S. President Donald Trump’s former campaign aide Barry Bennett.


Avenue Strategies filed paperwork with the U.S. Justice Department in February, registering as an agent to promote Tymoshenko through a company called Two Paths LLC for a monthly retainer of $65,000.

ITBC’s total payments to Livingston and Munson also amount $65,000 a month.

Jurisdiction in the state of Delaware allowed Two Paths to conceal its ownership, but the contract with Avenue Strategies was signed by a New York-based Ukrainian-American lawyer Marlen Kruzhkov, who boasts having “high-net worth individuals in Russia, Ukraine, and other former Soviet countries” among his clientele.

Back then, Tymoshenko responded by saying that the contract with Avenue Strategies had been signed in her interests but without her knowledge and sanction. However, media reported that in the fall of 2017 she met with Avenue Strategies’ partner George Birnbaum and political consultant Vlada Galan in Kyiv.

“I’m very grateful to you and the people who financed the contract with the lobbyists to assist me and Ukraine,” Tymoshenko wrote in a letter to Two Paths LLC from April 11. “I am certain that your actions stemmed from your concern for the fate of Ukraine. I highly appreciate that you associate me with the future of our country.”


A month later Two Paths terminated the contract.

Livingston Group

Bob Livingston says his client ITBC is “an American company comprised of a number of people concerned about the future of Ukraine, especially in these days of accelerating Russian aggression.”

“At their request, we are and shall be facilitating visits to the U.S. by various current and/or potential Ukrainian officials. We do not represent specific current or potential office holders,” he replied in an email to the Kyiv Post.

Those “persons supporting reform in Ukraine” believe that “Tymoshenko is best suited to lead Ukraine in its ongoing battle with Russian military and economic aggression,” according to the correspondence Livingston sent out inviting Capitol Hill and state officials and think tanks to meet with the Batkivshchyna leader.

The Livingston Group’s registration as a foreign agent for ITBC makes no mention of Tymoshenko, but informational materials and a supplemental statement filed with the U.S. Justice Department show that the firm exclusively promoted Tymoshenko’s visit to Washington D.C., which was postponed twice before eventually going ahead in December.

Tymoshenko’s meeting on Dec. 5 with the officials of the International Republic Institute, namely president Daniel Twining and regional director for Eurasia Stephen Nix, was arranged by the Livingston Group, as the IRI’s press secretary Julia Sibley confirmed to the Kyiv Post.


Tymoshenko also met with Clifford May, the president of the Foundation for Defense of Democracies, a conservative policy institute, and Derek Mitchell, the president of the National Democratic Institute, a nonpartisan non-government organization to support democracy worldwide. Both had been contacted by The Livingston Group in August.

Livingston Group’s FARA disclosure only lists its work for ITBC from July and September, and it is likely that other meetings of Tymoshenko with U.S. senators could have been arranged later in fall.

Tymoshenko isn’t the first Ukrainian representative Livingston has set up with Washington D.C. decision- and policy-makers.

Earlier this summer, the firm arranged meetings for Natalia Mykolska, then-Deputy Minister of Economic Development and Trade of Ukraine, during her visit to Washington D.C. to discuss the 25 percent tariff imposed by the administration of U.S. President Donald Trump on steel imports.

The Livingston Group was hired for $20,000 short-term by Ukrmetalurgprom, an association of Ukrainian steel producers, including oligarch Rinat Akhmetov’s Metinvest, Viktor Pinchuk’s Interpipe, Kostyantyn Zhevago’s Ferrexpo, and Luxembourg-headquartered corporation Arcelor Mittal.

“We consulted with our member companies, and one of them suggested Livingston as an experienced firm,” head of the association Oleksandr Kalenkov told the Kyiv Post.

The Livingston Group also represents North American Interpipe Inc, a Texas-based branch of Pinchuk’s Interpipe.

The Livingston Group appears to have worked with another person hired by ITBC, media consultant Naomi Decter Munson, not long ago on another project. Beckerman, a PR firm where Munson served as a senior vice president until recently, and The Livingston Group were among several U.S. lobbying and PR firms hired by Israeli consulting firm Mer Security and Communication Systems to handle the trips of a special envoy of the Democratic Republic of Congo to the United States.

According to Munson’s FARA registration as an agent for ITBC, she is responsible for organizing interviews with U.S. journalists for “Ukrainian-Americans and Ukrainians, including Yulia Tymoshenko,” arrange meetings with DC-based think tanks, and assist in placing op-eds in support of reform in Ukraine.

Munson is a former journalist and comes from the Podhoretz family of Republican neoconservative journalists and political commentators. She has not replied to a request to comment.

Aveiro LP

The idea of generous supporters sponsoring Tymoshenko’s promotion in the United States, one of Ukraine’s main allies, isn’t new.

In 2014, the London-registered Trident Foundation, comprised of “Ukrainian businessmen supporting a free, independent and democratic Ukraine,” hired two lobbying firms – Wiley Rein and MKW Group – to “provide political consulting services to Yulia Tymoshenko,” lawmaker Sergii Leshchenko wrote in 2015.

Trident’s listed director was a Dnipro native Mykhailo Sokolov, a former lawmaker from the Batkivshchyna party and a long-time head of the party’s branch in Mykolayiv Oblast.

In March 2016, Trident Foundation terminated its contracts with Wiley Rein and MKW Group. Within days, Wiley Rein, run by a former Congressman Jim Slattery, filed documents with the U.S. Justice Department as an agent for a new client called Aveiro LP, a Northern Ireland-registered international trade and investment firm that supports a free, independent, democratic, and prosperous Ukraine.

“In reality, it (Aveiro LP) was spending money on Washington lobbyists on behalf of unidentified Ukrainian interests, and there was no way of finding out who they were,” wrote British journalist Oliver Bullough in his 2018 book Moneyland on tax havens and shell companies used by the super-rich around the world.

As opaque as it is, Aveiro LP opens a door into a labyrinth of British-registered shell firms connected through two partner entities – Nisbett Invest S.A. and Montfler S.A.

Aveiro LP’s listed director is a Ukrainian citizen, Uliya Bilousova, who also appears as a director of a Scottish-registered Gallteks Project LP, which was sanctioned by the Ukrainian government in 2016 for owing over $800,000 to two Chernivtsi companies. Gallteks Project LP banked in a small Estonian bank Versobank AS, which was shut down for money laundering earlier this year.

Wiley Rein serviced Aveiro LP up until June 2018. According to its FARA filing, the lobbyists organized individual meetings for an undisclosed client with several senators and Congressmen, Senators Marco Rubio, Bill Nelson, and Bob Corker among them, between February 6 to 8. Tymoshenko was in Washington at the same time, and reportedly met with Rubio, Nelson, and Corker.

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