State officials in Florida may have dissolved a company linked to a Ukrainian American businessman facing campaign finance charges long before Rudy Giuliani’s consulting firm reportedly was paid $500,000 to provide business and legal advice.

The company in question is called Fraud Guarantee. Its website lists as its co-founder and CEO Lev Parnas, who allegedly worked with Giuliani to urge Ukrainian officials to investigate Democratic presidential candidate Joe Biden and his son Hunter. Parnas was indicted last week on charges that included making an illegal campaign contribution through a shell corporation to a PAC that supported President Donald Trump in the 2016 election.

Parnas also listed himself as the CEO of Fraud Guarantee when making large contributions to Republican candidates and PACs in 2016, according to Federal Election Commission records.

Giuliani, Trump’s personal lawyer, told Reuters on Monday that Fraud Guarantee hired his firm in August 2018. In an earlier interview with The New York Times, Giuliani appeared to make contradictory statements about whether he had advised the company.

An attorney for Parnas, John M. Dowd, declined to discuss his client with CQ Roll Call in a phone call before hanging up. Dowd previously represented Trump. Giuliani Partners did not respond to requests for comment.

Murky history

Like so many things related to alleged attempts to get Ukrainian officials to investigate the Bidens — and the impeachment inquiry it unleashed — the corporate history of Fraud Guarantee is murky.

In the search for Fraud Guarantee, three names that all appear to have links to Parnas emerged: fraudguarantee.com, Strategic Global Assets LLC and Fraud Guarantee LLC.

Florida Department of State records show that Strategic Global Assets LLC registered fraudguarantee.com as a fictitious name in March 2013. Strategic Global Assets’ corporate filings list Parnas and Florida businessman David Correia as managers. Correia was also among the defendants in the indictment unsealed last week. He was arrested in New York on Monday. 

The Florida Department of State dissolved Strategic Global Assets in September 2016 after it failed to file an annual report, records show.

That was about two years before Giuliani told Reuters his company was hired by Fraud Guarantee and about a month before Parnas made the campaign contributions as its CEO.

A lawsuit was filed against Strategic Global Assets for failure to pay rent in Palm Beach County, Fla., in January 2015, and a default judgment in the landlord’s favor came down in July of the same year.

Strategic Global Assets’ official address on state records was changed in September 2015 to that of Correia’s apartment at the time. Correia was listed as the registered agent for Strategic Global Assets in that same filing. He is identified as Fraud Guarantee’s co-founder and chief operating officer on that company’s website.

Florida records show that another company called Fraud Guarantee LLC was dissolved in September 2014 for failing to file an annual report. It’s not clear whether that company was associated with Parnas or Correia, but it shared the same street address that appears for Strategic Global Assets and fraudguarantee.com on Florida court records and an archived copy of the company’s website.

Parnas and Correia worked together for many years, and their businesses have been involved in repeated litigation.

CQ Roll Call searched for corporate records related to Strategic Global Assets nationwide. Companies called Strategic Global Assets LLC were also registered in Delaware in May 2013 and New York in 2010, according to records in those states.

Officials in Delaware dissolved the company there in November 2014 because it did not appoint a registered agent. The company in New York appeared to change its name in 2010 to Boone Strategic Ventures LLC. Online state records do not list its phone number or the names of its principals, and no one answered the door Wednesday at the New York City residential building that is listed as its address.

Giuliani declined to tell Reuters whether he was paid directly by Fraud Guarantee but said that the money he received for his work with the company “did not come from foreigners.”

It is possible that Parnas and Correia operated Fraud Guarantee outside the corporate structure they set up in Florida, said Gary McGill, director of the Fisher School of Accounting at the University of Florida.

“Individuals may refer to ‘companies,’ but they may be using a very loose and non-legal definition of what that means,” said McGill, an expert in business accounting.

“So it is possible to operate through an entity, or a partnership-type entity, that doesn’t necessarily show up in state records as an LLC,” he added.

If the two men were operating through the company in Florida after it was dissolved, however, that could run afoul of state law, said Yekaterina Mesic, a lawyer and former assistant state attorney in Jacksonville, Fla.

“Once it’s dissolved … the company continues to exist, but the only thing they can do is basically wind up the affairs,” Mesic said. “Sell the stuff, pay the employees, et cetera.”

Illegal contributions alleged

In the indictment last week, federal prosecutors alleged that Parnas and Igor Fruman, a U.S. citizen born in Belarus, formed a company called Global Energy Producers LLC to conceal the source of illegal campaign contributions made in its name.

FEC records show that in May 2018, Global Energy Producers contributed $325,000 to America First Action, a pro-Trump PAC, and $15,000 to 35th Inc., a PAC that supported West Virginia Attorney General Patrick Morrisey’s failed 2018 Senate run against Democratic Sen. Joe Manchin III.

FEC records show that Parnas also appears to have made large contributions to Republicans in 2016 and 2018 while identifying himself as an executive with two other companies — Global Energy Producers and Loan Crime Investigative Group. In two instances, his occupation was not listed.

In addition to Parnas, Fruman and Correia, the federal indictment identified a fourth defendant: Andrey Kukushkin, a U.S. citizen born in Ukraine. The indictment also referred to “Foreign National-1,” a Russian citizen who allegedly made two wire transfers from a foreign bank account totaling $1 million that were used “to make maximum donations to two political candidates for State office in Nevada.”

Those candidates reportedly are Republicans Adam Laxalt, a former state attorney general who lost his bid for governor last year, and Wesley Duncan, once Laxalt’s top deputy, who made an unsuccessful bid for his boss’s old job.

Parnas and Giuliani appear to be close. A cellphone video taken last year shows Giuliani, Parnas and Fruman arm-in-arm at Trump International Hotel in Washington, as they record a message to Rabbi Moshe-Reuven Azman, an influential religious leader in Ukraine.

“I can’t wait to come back,” Giuliani said as he smiled broadly for the camera. Fruman, like Parnas, allegedly tried to convince Ukrainian authorities to investigate the Bidens as emissaries for Giuliani.

Giuliani, Parnas and Fruman met at Trump’s D.C. hotel again just hours before federal agents arrested Parnas and Fruman at Dulles International Airport. The two had one-way tickets to Vienna, where Giuliani was reportedly scheduled to travel later that same day.

Dean DeChiaro contributed to this report.