Amr Alfiky / Reuters

If the grassroots right wants to “drain the swamp” in Washington, D.C., it can’t ignore the suspicious behavior of Rudy Giuliani. Here’s one red flag: Wealthy, powerful people tend to pay their lawyers top dollar. But as Donald Trump’s personal attorney, Giuliani works for free. In fact, an attorney representing Giuliani’s wife in divorce proceedings told the New York Post that he’s losing money. “Not only does he work for free, but all of his expenses every time he goes down to Washington, D.C., every time he travels for the president, it comes out of his own pocket,” the divorce attorney explained, “and he won’t say how much it’s costing him.”

Why has the former New York City mayor taken on a billionaire as a charity case? It’s not clear, and neither is the nature of the work he’s done relating to Ukraine, a subject of interest in the House impeachment inquiry. At times, Giuliani has described his Ukraine meddling as heroically public-spirited, declaring that “I’m not acting as a lawyer.” He once told a Fox News host, “I wasn’t operating on my own; I was operating at the request of the State Department.” Yet on a different occasion he said, “This isn’t foreign policy,” but help for “my client.”

None of those explanations is satisfying even apart from the contradictions. Attorneys don’t normally work gratis for anyone with deep pockets. And as Trump recently told Bill O’Reilly, “Rudy has other clients, other than me. He’s done a lot of work in Ukraine over the years.” One cannot conclude unethical behavior from Giuliani’s anomalous financial arrangement with Trump or his lucrative ties to foreign interests. But those red flags demand scrutiny of his business dealings, at least for anyone earnestly trying to drain the swamp of self-dealing elites, since he has access to the president and an incentive to monetize it.

A review of publicly available information is eye-opening. Giuliani has worked with multiple clients who could benefit bigly from influencing U.S. foreign policy and various presidential actions or inactions, as I discovered while delving into a decade’s worth of news articles about his businesses, hoping to understand how they make money. Indeed, it looks as though even as Giuliani was attacking Hunter Biden for accepting a swampy position on the board of a Ukrainian energy company, appearing to monetize his ties to his then-vice-president father, Giuliani or his partners were in contact with clients and potential clients who could profit from Giuliani’s ties to Trump.

That would explain the anomalous behavior: Perhaps Giuliani doesn’t take money from Trump because Trump’s not the client, but the product.

To understand Giuliani’s businesses, first recall how beloved the New York mayor became after the 9/11 attacks. The issue of Time declaring him 2001’s Person of the Year gives a sense of his stature:

When the day of infamy came, Giuliani seized it as if he had been waiting for it all his life, taking on half a dozen critical roles and performing each masterfully … He became America’s homeland-security boss, giving calm, informative briefings about the attacks and the extraordinary response. He was the gutsy decision maker, balancing security against symbolism, overruling those who wanted to keep the city buttoned up tight, pushing key institutions—from the New York Stock Exchange to Major League Baseball—to reopen and prove that New Yorkers were getting on with life. He was the crisis manager, bringing together scores of major players from city, state and federal governments for marathon daily meetings that got everyone working together … Giuliani’s performance ensures that he will be remembered as the greatest mayor in the city’s history.

After leaving office, Giuliani found ways to monetize his reputation. “He founded a number of eponymous companies,” Foreign Policy reported, “including the security and management consulting firm Giuliani Partners, as well as Giuliani Security & Safety.”

The New York Times found evidence of clients residing in countries as varied as Qatar and Canada, and tied Giuliani to TriGlobal Strategic Ventures, a company that helps Westerners with business opportunities in the famously corrupt former Soviet Union, including Ukraine.

The article gives specific examples of Giuliani’s work in the region. In 2004, TriGlobal “arranged to have Mr. Giuliani come to Moscow to meet with the foreign minister, Sergey V. Lavrov, as well as other prominent Russian politicians and business executives … In 2015, also at the company’s behest, Mr. Giuliani agreed to advise the mayor of Kiev, Vitali Klitschko, who has called for more Western support of the Ukrainian government’s efforts to combat Russian separatists.”

House investigators have sought “documents and depositions from two of Giuliani’s current clients, Florida-based business executives who have been pursuing opportunities in Ukraine for a new liquefied-natural-gas venture, The Washington Post reports, and “records about Giuliani’s past clientele in Ukraine, including Pavel Fuks, a wealthy developer who financed consulting work Giuliani did in 2017 for the city of Kharkiv.”

Fuks appears actively interested in buying access to the Trump administration: According to The New York Times, he paid $200,000 for what he thought was a VIP ticket to Trump’s inauguration, then filed a lawsuit alleging that he was cheated in the deal. “He never received the tickets he said he was promised to an official inaugural ball, to a dinner with incoming cabinet members or to other exclusive events,” the newspaper reported.

Journalists for the foreign publication Censor.net later pressed Giuliani about his consulting work circa 2017. “Many people in Ukraine are wondering about the nature of your connections with Mr. Kernes, the mayor of Kharkiv,” they declared. “Because he does not have an exactly clean reputation in Ukraine. But you visited him in Kharkiv. And we’d like to know what’s connecting you.”

Giuliani replied that his company did a study for Kharkiv; that he visited the city in November 2017 to present recommendations, including the construction of an emergency-management center; and that he met with the mayor and his deputy.

What he said next is especially worth flagging:

Because to build it, as I can imagine, you have to get some money from the national government. And I explained to him why they needed emergency management center and how they work, how emergency management centers work. We’ve done this all over the world. I’ve done security assessments, I’m doing it now. Mostly in South America, Eastern Europe and Middle East. But also in countries all over the world. That’s my business.

In other words, Giuliani described himself as lobbying the national government of Ukraine to direct money in a manner that would benefit his client. That would make influence or leverage over Ukrainian leaders a clear asset in his business. And Trump later pressured Ukraine’s new president to talk with Giuliani.

There’s more. The New York Times reported last week that as Giuliani was trying to unearth damaging information about the Bidens in Ukraine, he simultaneously pursued hundreds of thousands of dollars in business from Ukrainian government officials.

Even as Giuliani urged Yuriy Lutsenko, then Ukraine’s top prosecutor, to investigate the Bidens, one draft proposal called for Lutsenko to pay $200,000 to Giuliani Partners to represent him. “I never received a penny,” Giuliani told the newspaper, claiming he concluded that representing the prosecutor personally would be a conflict of interest. Yet Giuliani kept pursuing a different way to get paid through Lutsenko, the Times article continues:

Mr. Lutsenko also wanted to hire Mr. Giuliani to help recover Ukrainian assets. An updated proposal was circulated a few days later, along with instructions on how to wire money to Giuliani Partners. This version made no mention of Mr. Lutsenko, but instead sought $300,000 from the Ukrainian Ministry of Justice and the Republic of Ukraine. The proposal was signed by Mr. Giuliani, but not by the justice minister at the time, Pavlo Petrenko.

Giuliani told the Times that when he pursued that $300,000 deal, which never came to fruition, “it did not come out of my desire to make a lot of money,” a difficult assertion to accept.

Giuliani’s Ukraine dealings aren’t alone in warranting scrutiny. For example, The Washington Post reports that when Giuliani traveled to Madrid in August to confer with an aide to the Ukrainian president, he also met with a previously unidentified client, staying at “a historic estate belonging to Venezuelan energy executive Alejandro Betancourt López, who had hired Trump’s personal attorney to help him contend with an investigation by the Justice Department into alleged money laundering and bribery, according to people familiar with the situation.”

A foreign energy executive hiring the president’s personal attorney to fight a federal agency led by the president fits my personal definition of swampy behavior. Isn’t that at least as ethically suspect as what Hunter Biden did?

There’s no way of knowing every deal that Giuliani or his business associates have struck in Ukraine or elsewhere—but the tiny subset that I’ve highlighted shows huge conflicts of interest with respect to clients whose interests diverge from those of the American people.

And there’s a matter of possible illegality that I haven’t mentioned: A federal investigation into two associates of Giuliani, Lev Parnas and Igor Fruman, “is exploring a wide range of potential crimes—including wire fraud and failure to register as a foreign agent—as prosecutors dig into the pair’s interactions with the president’s personal lawyer and the main pro-Trump super PAC, according to people familiar with the investigation,” The Washington Post reports. The Post previously reported that Giuliani’s firm “was earning $500,000 from Parnas” for work conducted on behalf of a “Florida-based business called Fraud Guarantee,” a lucrative arrangement that started “just as Giuliani began working closely with Parnas and a business partner, Fruman, to dig up dirt on Democrats in Ukraine.”

The Wall Street Journal reports that a Florida investor helped underwrite the payment to Giuliani by investing in Fraud Guarantee “after Mr. Parnas told him his plan was to secure a $20 million federal grant,” adding, “The Journal couldn’t determine what the grant would fund.” The article quotes Giuliani responding, “I had no knowledge of a grant, and it seemed to me they were at a premature position to be looking for a grant.”

What exactly did that $500,000 buy?

At American Greatness, a Trump-aligned web publication, Ned Ryun, a former George W. Bush speechwriter, complained that “the mainstream propagandists gaslight us by shrieking that Trump is the corrupt one.” I would not call Trump “the” corrupt one, as if he is alone in the category. I’ve written multiple times about Clintonian corruption. When Trump leaves office, there will be corruption left to write about. But in my estimation, there is no excuse left for failing to see that Trump is a corrupt one, surrounded by corrupt ones.

Even if Giuliani hasn’t broken the law, it sure looks like he leverages his relationships with deep-pocketed donors and high-ranking government officials to sway policy and benefit elite clients––and that working for free for a billionaire president helps.

Trump’s supporters enable this corruption when they credulously assume that Trump and his allies are fighting corruption and draining the swamp, rather than scrutinizing their most suspicious behavior to see if they are perpetuating the swamp.

Trump’s previous personal attorney, Michael Cohen, wound up in prison, and his former campaign manager, Paul Manafort, agreed to work for Trump free of charge before winding up in prison as well. Now Trump has a new personal attorney who agrees to work for free and folks who say they want to drain the swamp aren’t suspicious? That degree of tribal loyalty and incuriosity damages any republic that relies on government by the people.

Wake up, MAGA nation!

We want to hear what you think about this article. Submit a letter to the editor or write to letters@theatlantic.com.