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Russia VTB Bank DC Meets FARA & LDA 3 of 3

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Posted on June 07 2018


As previously discussed here


And here’s your obligatory Spicy disclosure:

There's nothing illegal about lobbying. Sure it -can- look bad in the Court of Public Opinion, but in the Court of Law, there’s nothing wrong or untoward about hiring a firm to lobby on your Country/Business behalf. As such nothing in this entry or previous entries should be construed that any of these firm did anything illegal or unethical.

Conversely when any Foreign entity, such as a Foreign Government and/or a Foreign Business or in some cases both,  spends millions of dollars lobbying. One has to drill down on the Who/Why/What/When of said lobbying efforts. It’s also a good idea to read the FARA filings in both context and content. Specifically pay attention to the various real world events of said lobbying efforts. By ignoring the “context” it’s possible you may not fully understand the “content” or may inadvertently gloss over the totality of both.

I purposely waited to discuss FARA #3731, partly because I wasn’t happy with the level of my research. I felt this entry deserved a deeper and mostly importantly an impartial data driven dive. Again at all times I will link to data source. So let’s go ahead and pull the ripcord.


Sidley Austin, LLC:

True story, after President Lincoln’s assasination, former First Lady Mary Todd Lincoln hired this firm to manage personal and family matters, specifically related to the Estate of President Lincoln. 

This firm is arguably one of the top 5 firms in the Country, they have annual revenue in excess of $2Billion. In 2017 they employed more than 1900 Attorneys with offices 20 offices worldwide. It’s known as a “full service” firm offering clients a vast portfolio of services. Simply put, if you want a top tier law firm, who specializes in lobbying, you’d want to hire Sidley Austin. This firm is the “gold standard”, as a whole the firm is widely respected, they treat their employees exceedingly well and will move mountains for their clients.


Sidley Austin

🇷🇺FARA #3731 VTB Bank🇷🇺

So naturally is makes sense that VTB Bank would hire Sidley Austen. After a bit of research, I was able to determine VTB Bank, not their JV or Subsidiaries hired the firm on April 2, 2015. That's the date on the signed Letter of Engagement (LOE). Furthermore, there’s a very important distinction, see  pages 5-11 of  FARA #3731 -Exhibit AB which was filed with the Department of Justice on October 23, 2015 at 12:17:20 found here, which reads in part:


Client: Scope of Representation

The client in each Matter will be VTB Bank ("you" or the "Client"), and not any other subsidiary or affiliate of yours, nor any of your or their respective individual shareholders* directors, officers or employees


The initial Matter is the provision of government strategies counsel and advice and lobbying directed toward the United States Congress and Administration on behalf of VTB Bank regarding the imposition of sanctions by the US government on Russian-affiliated banks. With respect to any Matter* you may limit or expand the scope of our Representation from time to time...


See page 6 (of FARA filing, concurrently marked as page 2 of LOE). Notice the subpoena language? It’s almost verbatim of the Manatos & Manatos LOE, found here

If Sidley is required to respond to a subpoena or other formal request from a third party or a governmental agency for records or other information relating to the Representation, or to testify by deposition or otherwise concerning the Representation


I now refer you to pages 7 & 8 of the aforementioned FARA filing (concurrently marked pages 3-4 of the LOE), VTB Bank agreed to a monthly retainer fee of $40,000 and separate cost for time and materials. (put a pin in that, it will make sense as I drill down on subsequent VTB & Sidley FARA filings.) and Sidley & VTB potential “future” Conflict of Interest. The rest of the LOE is pretty standard. 



I don’t know if this matters but I noticed in this LOE both Sidley & VTB Bank agreed that Sidley would be “the lead” on lobbying efforts. Yet oddly in VTB LOE for Manatos & Manatos. That firm also claimed the “lead lobbyists” role, my educated guess is the LOE for Manatos & Manatos shows VTB Bank JV, whereas the LOE for Sidley cites “VTB Bank” and specifically carved out any VTB subsidiaries.

So now we know WHEN the Sidley & VTB lobbying relationship started, it was in October of 2015. Now let’s dive in to the aggregate bi-Annual FARA #3731 reports. Again at all times I will link to a data source, starting with the most recent 2018 FARA Report. Just a friendly reminder each FARA Supplemental Statement covers the previous 6 months.


April 2018 FARA #3731 🇷🇺VTB Bank🇷🇺

Supplemental Statement filed on April 19, 2018 link found here. This report covers the time frame of October 2017 thru March 2018. I now refer you to pages 19 & 20.

During this 6 month period VTB Bank paid Sidley Austen some $307,749,59 in lobbying and legal fees and a subsequent $27,767.74 in administrative cost associated with Postage, telephone, telex, messenger service, photocopying and document processing.



There is 1 anomaly in this FARA filing, its the $60,000 payment made on January 18, 2018. As a reminder the agreed upon month retainer fee between Sidley & VTB Bank was $40K (as previously noted in the aforementioned 2015 LOE between both parties). Said monthly retainer fee appears to have been paid on January 27, 2018. So naturally when you see a payment that exceeds the monthly retainer fee, that’s something you should carve out and drill down on. Now the next question you should ask: what was going on in January 2018?

Luckily I have a factual answer for you. Remember on July 27, 2017 the Russian Sanctions bill passed both Chambers of Congress with a Veto proof majority; House 419/3 and Senate 98/2 see CNN Article here. These sanctions and various Oligarch Reports were statutorily required by Oct 1, 2017, yet after nearly four months of unexplained delays, in late January of 2018 the Trump Administration, specifically the US Treasury finally submitted the report. Which was widely panned because it was clear Sec Mnuchin essentially cribbed the Forbes Magazine list Russian Oligarchs, see US Treasury January 26, 2018 “Announcement” here


Countering America's Adversaries through Sanctions Act (CAATSA) unclassified list of Oligarchs pursuant to Section 241, list can be found here.


Remember how I’ve tweeted over and over again that The Department of Justice (DOJ) on a bi-Annual basis submits a FARA Report to The Congress? That’s not me being hyperbolic, by law the DOJ is required to submit FARA reports.

I now refer you to page 180 of the DOJ June 2017 FARA Report, found here.

Where by you can read the DOJ report and potentially realize, that VTB Bank had a >170% increase in money spent on lobbying:

2017 Sidley Austin, LLP #3731 JSC VTB Bank

Nature of Services: Lobbying.

The registrant provided legal advice on United States laws and regulations.

$181,754.60 for the six month period ending March 31, 2017


 Should you be inclined to double check my research:

    • Step 1, identity the FARA # (Sidley Austen FARA # is 3731)
    • Step 2, click on this DOJ/FARA link 
    • Step 3, use the drop down and select ALL, type in FARA #
    • Step 4, a Report populates
    • Step 5 click on the report link & enjoy.


Remember how the Sidley Austen & VTB Bank decreed that Sidley Austen would be VTB Bank’s “sole lobbyist” funny when I searched the House & Senate LDA Database it appears that Manatos & Manatos actually performed a vast majority of the Sanctions Lobbying for VTB Bank. Link to LDA Database can be found here.


-Spicy Out

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