The increased activity of the UAE lobby in the US following rising scrutiny of Emirati support for a militia accused of genocide in Sudan.

Background

The United Arab Emirates (UAE) is accused by UN experts of arming the Rapid Support Forces (RSF) militia that, according to the US, has committed genocide in Sudan. Amid campaigns to ban US arms sales to the UAE, a key obstacle to such activism is a powerful UAE lobby in the US that has even aroused the concerns of American intelligence officials.

Indeed, a classified report from 2022 revealed the “UAE’s bid, spanning multiple US administrations, to exploit the vulnerabilities in American governance, including its reliance on campaign contributions, susceptibility to powerful lobbying firms and lax enforcement of disclosure laws intended to guard against interference by foreign governments”.

Executive summary

On 17 January 2024, the outgoing US President Joe Biden administration will report to the US Congress on the UAE’s assurances that it is not arming the RSF. This comes after legislation filed in both the House of Representatives and Senate to halt US arms sales to the UAE until it can be guaranteed that it is not supporting the RSF.

Amid the likelihood of Emirati lobbying, an exclusive Sudan In The News’ investigation took a detailed look into the UAE’s lobby in the US, with a particular focus on its activities related to Sudan. Following a comprehensive analysis of the Foreign Agents Registration Act (FARA) documents filed after the outbreak of war in Sudan by organisations hired to work for the UAE Embassy in Washington, we extracted data that enabled us to identify patterns and themes in UAE’s attempts to influence decisions in the US.

The activity of two firms – Terakeet and TRG Advisory – were not covered in the report as their work is related to search engine optimisation and podcast production respectively. Instead, we assessed the work of the following five firms engaging in explicitly political work on the UAE’s behalf:

· American Defense International (ADI)

· Akin Gump Strauss Hauer & Feld

· FGS Global

· Gilliland & McKinney (G&M)

· Bullpen Strategy Group

Starting shortly before April 2023, the UAE spent at least $14,373,691 on those five firms. The aforementioned firms made at least $1,040,384 in political contributions* with 18.7% of that - $195,407 - given to Senators and House Representatives contacted on the UAE’s behalf. The report found that lobbying activity on the UAE’s behalf increased after December 2023 following a letter from ten Democrat House Representatives led by Sara Jacobs calling for the UAE to end its support for the RSF.

ADI

ADI registered the most activity related to Sudan. This revolved around communicating with members and staff of the House Armed Services Committee regarding allegations of the UAE’s support for the RSF, and included inviting Jacobs’ legislative director to a meeting with the UAE ambassador.

ADI’s lobbying activity on the UAE’s behalf almost quadrupled from 19 between August 2023 and January 2024, to 71 from February to July 2024. This activity particularly surged in summer 2024 after Jacobs introduced legislation proposing limiting arms sales to the UAE. The data enabled us to deduce ADI’s strategy, as we identified a trend of ADI targeting individuals of influence in the US Congress, particularly its Armed Services (HASC) and Foreign Affairs (HFAC) committees.

Akin

Law firm Akin registered the most activity out of the five organisations covered. Like ADI, their activity on the UAE’s behalf significantly increased from 2023 and 2024. The 105 contacts made by Akin from July to December 2023 more than tripled to 327 from January to June 2024.

This came after the December 2023 Jacobs-led letter calling on the UAE to stop supporting the RSF, after which Akin directly communicated with the staff director of the House Subcommittee on Africa – who has since gone on to work for Jacobs.

In addition, Akin also made the most contributions out of all the firms covered, including to Jacobs herself after her proposed legislation limit US arms to the UAE.

FGS Global

The third firm covered is FGS Global. They are the highest-paid out of the five, a figure that also takes into account the work they do for the UAE’s Mission to the UN. Their registered activity also increased from the end of 2023 to 2024. However, the documents suggested that their work mainly revolves around media relations covering regional affairs, with no mention of Sudan or the RSF.

G&M

While documents submitted by Gilliland & McKinney (G&M) made no mention of Sudan, we nonetheless learned that their funding from the UAE Embassy has continued to rise since the outbreak of war in Sudan on 15 April 2023. This reflects the UAE’s increasing investment in its US lobby.

Bullpen

Finally, we reviewed the filings of Bullpen Strategy Group – the rebranded successor to a firm specialising in negative publicity about its client’s rivals. Their registration was the most discreet about the five, giving little clues about the nature of their work for the UAE beyond reference to issues related to Qatar.

*Legal note

Ahead of any discussion on the political contributions of organisations registered to work on the behalf of UAE clients, we stress that there is no indication of any illegality or that funds from the UAE were used to make these contributions. The latter would be a violation of the US Federal Election Commission’s prohibition on contributions from non-US nationals. It is worth noting that lobbying firms working for UAE clients have diverse sources of revenue, including domestic clients, from which contributions can be made. Even if a lobbyist is representing a foreign government, there is no US law that forbids an elected representative from accepting a contribution from them on the same day of communication.

Glossary

Below are definitions for terms and acronyms related US politics that are commonly used throughout this report.

Foreign Agents Registration Act (FARA): A US law that requires individuals and entities who represent foreign interests to register with the Department of Justice (DOJ) and disclose their activities, relationship, and financial compensation.

Supplemental Statement: Organisations lobbying on behalf of foreign goverments usually file a Supplemental Statement to the FARA registry every six months. They are meant to detail their activity and political contributions.

US Congress: As the legislative branch of the US’ federal government, the US Congress has an upper body (the Senate) and a lower body (the House of Representatives).

Senate: The Senate is the upper chamber of the US Congress. Its elected members are known as Senators.

House of Representatives / the House: As the lower chamber of the US Congress, the House of Representatives makes and passes federal laws. It is frequently to just ‘the House’. Its elected members are known as ‘House Representatives’.

House Foreign Affairs Committee (HFAC): This committee oversees and shapes US foreign policy and international relations. It has 51 members (27 Republican, 23 Democrat).

House Armed Services Committee (HASC): This committee plays a key role in authorising US defence spending and shaping defence policy. It has 59 members (31 Republican, 28 Democrat).

Ranking Member: While the most senior member of the majority party in a committee is called the chairperson, their counterpart on the minority party is known as the ranking member.

Majority Leader: This is a key leadership position in both the House and Senate, representing the party that holds the majority of seats in the respective bodies.

House Speaker: Elected by members of the House, the Speaker is responsible for maintaining order during sessions, overseeing legislative procedures and ensuring that rules are followed.

National Defense Authorization Act (NDAA): This is an annual piece of US legislation that authorised the budget and sets policies for the Department of Defence (DoD). It has provisions related to arms sales, particularly those involving foreign military sales. Thus, the NDAA can impose restrictions or limits of US arms sales to certain countries.

1. AMERICAN DEFENSE INTERNATIONAL

Out of the five firms lobbying on the UAE embassy’s behalf in the US, American Defense International (ADI) ranks third in terms of both fees received and political contributions made to US politicians. Since the outbreak of war in Sudan, ADI has registered the most communications with US political stakeholders on matters directly related or relevant to Sudan. This is why, alongside revealing the data on ADI’s financial influence on the US political ecosystem, we will also explore their lobbying on the UAE’s behalf and deduce their strategies.

ADI’s activity significantly increased in 2024 amid increased media scrutiny of the UAE’s support for the RSF and legislative attempts to block US arms to the UAE. The lobbying firm particularly targeted individuals who influence US Congress committees that have the ability to impact whether those legislative attempts succeed. It must be emphasised how ADI made significant financial contributions to the offices or campaigns of many of those individuals, reflecting the firm’s financial influence in Washington.

1.1 FINANCIAL

This sections covers the fees received by ADI from the UAE Embassy in Washington, alongside ADI’s payments to the offices of influential US politicians that they have contacted on the UAE’s behalf.

1.1.1 Fees

The UAE embassy in Washington has a $55,000 a month contract with ADI “to provide government affairs advice” until 31 December 2025. As of ADI’s last registration, it received $770,000 from the UAE between April 2023 and June 2024.

1.1.2 Contributions

A measure of ADI’s influence in Washington is the amount it has spent on contributions to the offices and campaigns of US House Representatives and Senators. With four of the five firms analysed in this report contributing at least $1,040,384 from 15 April 2023 to September 2024, ADI’s contribution of $106,904 – 10% of the overall sum - was the third highest.

Nonetheless, 25.4% of ADI’s contributions - $27,197 - went to politicians they contacted for lobbying on the UAE’s behalf. This included $4,550 given to Democrat House representatives Andy Kim and Mikie Sherrill, whose offices were contacted to directly discuss Sudan-related matters. A further $10,500 was given to House Speaker Mike Johnson and Majority Leader Steve Scalise, two senior Republican representatives contacted by ADI who have significant sway over potential legislation to block arms to the UAE due to its alleged support for the RSF.

1.2 OVERVIEW

ADI assists the UAE embassy with “US legislative and related policy matters potentially affecting the interests of the UAE including their engagement in Yemen, military sales from the [US] and relationship with the [US]”. This section will take a deeper dive into ADI’s lobbying activity on the UAE’s behalf following the outset of the war in Sudan on 15 April 2023.

ADI’s lobbying activity on the UAE’s behalf significantly increased after December 2023, amid increased US media scrutiny of the UAE’s support for the RSF and legislative attempts in January 2024 block US arms sales to the UAE for that reason. Indeed, ADI’s 19 communications in the six-month reporting period between August 2023 and January 2024 almost quadrupled to 71 in the following six-month period from February to July.

During that period, ADI reached out to influential US political stakeholders including US House Representatives, Senators and staff directors at the House Foreign Affairs Committee (HFAC) and House Armed Services Committee (HSAC). There are signs that ADI’s lobbying strategy on the UAE’s behalf was to target House Representatives who either sat on those committees or could significantly impact the success of legislation to limit US arms sales to the UAE due its support for the RSF.

ADI’s communication with US House representatives on Sudan-related matters also increased. Among those contacted included the offices of Democrat representatives that ADI made contributions to, alongside that of Rep. Sara Jacobs who led Democrats in calling for the UAE to end its support for the RSF and introduced legislation proposing blocking arms sales to the UAE.

As the focus of ADI’s lobbying became amendments to legislation governing arms sales, ADI not only targeted representatives and staff directors on the HFAC and HASC, but also representatives with significant influence over the legislative agenda who – crucially – were paid significant amounts by ADI. Finally, ADI registered its distribution of a letter to the Economist denying allegations that it backs the RSF.

Sudan-related matters (December 2023-January 2024)

The first time that ADI registered outreach to US political influencers regarding the war in Sudan was December 2023. Three communications are of particular relevance.

· 15 December 2023: ADI responded to a question from Marc Cevasco, the Chief of Staff of Democrat Representative Ted Lieu, “regarding news about UAE support for Sudanese paramilitary group”.

· 5 January 2024: Cevasco was contacted to discuss “alleged UAE support for the Rapid Support Forces in Sudan”.

· 5 January 2024: ADI reached out to Jessica Steffens, a senior staff member at the House Committee on Foreign Affairs, regarding a Joint Resolution introduced a day earlier by Democrat Rep. Ilhan Omar. Proposing the blocking of US arms sales to the UAE, Omar said: “The [UAE] have been violating the UN arms embargo in Darfur to support the RSF”.

The aforementioned communications were only three of 19 in ADI’s six-month reporting period between August 2023 and January 2024.

ADI’s increased lobbying activity (February-July 2024)

ADI’s contacts on the UAE’s behalf almost quadrupled to 71 in the following six-month period amid legislative attempts to limit arms sales to the UAE due to its reported support for the RSF. Between 2 February and 31 July 2024, ADI reached out to 33 US political stakeholders. They included:

27 US House representatives (12 Republican, 15 Democrat)
Two Senators (one Republican and one Democrat).
A Democrat staff director at the House Foreign Affairs Committee (HFAC).
Three Republican House Armed Services Committee (HASC) staff.

The documents suggest that ADI targeted people that sat on, or worked for, the Armed Services and Foreign Affairs committees of both the House and Senate. ADI reached out to 23 individuals who can influence either the House or Senate Armed Services committees. This included three Republican HASC staff. In addition, ADI contacted the staff of six Republican HASC members and 14 of their Democrat counterparts.

As for the House and Senate Foreign Affairs committees, ADI reached out to eight: two Republican politician staff, five Democrat politician staff and the Democrat staff director at the HFAC. Furthermore, ADI contacted House speaker Mike Johnson and Majority Leader Steve Scalise, both Republican.

Of ADI’s 71 contacts during the time frame, over half (44) were messages requesting or arranging meetings. The remaining 27 had more relevance to Sudan: 7 were directly related to allegations of Emirati support for the RSF, with 20 highly likely to be related to proposed legislation to limit US arms sales to the UAE.

1.3 SUDAN-RELATED MATTERS (April-July 2024)

On the UAE’s behalf between 11 April and 23 July 2024, ADI contacted five individuals. Four were staff members of Democrat House representatives who sat on one of, or both of, the HASC and/or HFAC. This included Cevasco, the Chief of Staff of HFAC member Rep. Ted Lieu, who was contacted again on 23 July to discuss “alleged UAE support for the RSF”. The next section, however, will focus on ADI’s communication with the offices of Reps Sara Jacobs, Mikie Sherrill and Andy Kim, as well as Chris Vieson, the Republican staff director at the HASC.

Democrat Congresswoman Sara Jacobs

On 11 April 2024, ADI had an in-person discussion “regarding alleged UAE support for the [RSF] in Sudan” with Brandon Mendoza, the legislative director for House Representative Sara Jacobs. Alongside sitting on the HASC, Jacobs is also on the HFAC, where she is a ranking member of the Subcommittee on Africa.

Even before ADI’s contact with Jacobs’ office, she was arguably the most influential US House representative campaigning for wider scrutiny of the UAE’s role in Sudan and reported support for the RSF. On 4 December 2023, she co-led a letter to US Secretary of State Antony Blinken seeking information about US strategies for atrocity prevention in Sudan which said: “it seems clear that the RSF has borne responsibility for the majority of atrocities” since the outbreak of war. Then, on 19 December 2023, Jacobs led a coalition of ten Democrat lawmakers calling for the UAE to end its support for the RSF.

On 22 May 2024, little over a month after ADI lobbied Jacob’s legislative director on the UAE’s behalf, legislation was introduced by Jacob proposing banning US arms sales to the UAE until it can be confirmed that the Emirates is not supplying the RSF. The legislation was referred to the HFAC. On the same day, Jacobs’ legislative director Mendoza received a text regarding “NDAA Amendment limiting weapon sales to UAE and potential future meeting with UAE Ambassador”.

The NDAA - the National Defence Authorization Act – is a series of laws specifying the annual budget and expenditures of the US Department of Defense, and as such, can potentially block or restrict US arms sales. Indeed, on 4 June 2024, Jacobs offered legislation proposing limiting arms sales to the UAE over its alleged RSF support as an amendment to the NDAA for the fiscal year 2025. However, Jacobs’ legislation was not adopted or referred to a committee.

Nonetheless, on 11 July, ADI had another discussion with Mendoza on “allegations of UAE activity in Sudan and proposed legislation”. This came three days after Jacobs penned an article for US political outlet The Hill which explained why she introduced the Stand Up For Sudan Act to prohibit US arms sales to the UAE until the US President Joe Biden administration can certify that the UAE is no longer providing material support to the RSF.

The importance of HASC Staff Director Chris Vieson (Republican)

The HASC plays a key role in shaping the NDAA as it oversees legislation governing US defence policy. This would explain why, alongside targeting politicians that sit on the HASC, the UAE lobby also contacts the committee’s staff members.

On 2 May 2024, ADI had telephone and in-person discussions on the UAE’s behalf with Chris Vieson, the Republican staff director at the HASC. According to the document, the purpose of the communication was “language in the NDAA dealing with the situation in Sudan”.

Vieson would have influence over potential legislation restricting arms sales to the UAE in his capacity as a staff director for Republicans who form the majority of the HASC. While unable to make final decisions, the staff director can shape the committee’s policy priorities, with their input potentially guiding final outcomes. In particular, the HASC staff director has significant sway in crafting language for bills such as the NDAA, which would explain why ADI contacted Vieson for this purpose.

Reps Mikie Sherrill and Andy Kim

In response to Jacobs’ legislation, ADI reached out to the offices of two Democrat representatives: Rep. Mikie Sherrill and Rep. Andy Kim. Both sit on the HASC which influences the NDAA, and crucially, ADI contributed a combined $4,550 to them before contacts were made.

On 1 July 2024, ADI emailed Sherrill’s military legislative assistant regarding Shaefer Bagwell regarding “alleged UAE involvement in Sudan and Sara Jacobs legislation to limit arms transfers to the UAE”. Bagwell was contacted again two days later for “constituent inquiries to Sara Jacobs legislation restricting arms sales to UAE”. ADI also provided Bagwell “with information regarding UAE response to global emergencies”.

It is worth noting that, after the outbreak of war in Sudan, ADI donated $1,250 to Sherrill before contacting her office on the UAE’s behalf. This included $500 given on 29 May 2024, a week after Jacobs introduced legislation proposing limiting arms sales to the UAE.

Nonetheless, the sum donated to Sherrill eclipse contributions to Andy Kim’s campaign – who received $3,330 from ADI on 18 March 2024. Like Jacobs, Kim sits on both the HASC and the HFAC. On 11 July, ADI had an in-person discussion with his military legislative assistant Nikitha Rai on “allegations of UAE activity in Sudan and proposed legislation”.

1.4 LOBBYING ON LEGISLATION TO LIMIT ARMS SALES

Between 15 May and 10 June 2024, ADI made 22 communications to US political stakeholders to discuss “NDAA Amendments that reference the UAE”. Five came on 21 May, a day before Jacobs introduced legislation proposing banning arms sales to the UAE until it can be confirmed that the UAE is not supplying the RSF. Another eight came on 3 June, a day before Jacobs introduced similar legislation as an amendment to the NDAA, which was eventually not adopted or referred to a committee.

Of those contacted, ten were US House representatives and four were staff directors at either the HASC or HFAC. Those committees were prioritised as ADI lobbied on the UAE’s behalf.

House Foreign Affairs Committee

Given the HFAC’s influence on foreign military sales, four individuals close to the committee were contacted by ADI. Two of them worked in the offices of Democrats representatives on the committee, including Jacobs’ legislative director Brandon Mendoza who, on 22 May, was also contacted regarding a “potential future meeting with UAE ambassador”.

On 3 June, ADI contacted the Chief of Staff of Gregory Meeks, the most senior Democrat on the committee. Although Meeks has no control over the HFAC agenda or final NDAA text – as Minority Leader he can shape the Democrat position on Jacobs’ proposals to limit arms sales to the UAE.

The Republicans contacted were HFAC staff director Brendan Shields and HFAC chairman Rep. Michael McCaul. As opposed to being contacted through his staff, McCaul was directly contacted by text and phone, reflecting ADI’s access to the HFAC committee’s chairman. From 15 April 2023 to September 2024, ADI contributed $5,802 that was split between six members of the HFAC. This pales in comparison to the amount given to HASC members.

House Armed Services Committee

A reflection of how important ADI considers the HASC in its lobbying attempts is the sum of contributions made. From 15 April 2023 to September 2024, ADI paid $20,872 that was split between 17 of the 59 member HASC. That sum reflects 19.5% of ADI’s political contributions during that period.

The HASC plays a key role in shaping the NDAA as it oversees legislation governing US defence policy. When it came to lobbying on the UAE’s behalf regarding NDAA amendments potentially limiting arms sales, the eight contacted by ADI were split in half between Democrats and Republicans. Out of the four Democrats, ADI engaged with the HASC’s Minority Staff Director Brian Garrett on 3 June 2024. In his role, Garrett has the ability to shape the debate and strategy around Jacobs’ proposed amendments, alongside coordinating the efforts of Democrats on the committee.

ADI also communicated with the offices of three Democrat Representatives on the committee. This included Ranking Member Adam Smith. As the lead representative of Democrats on the committee, he can set their agenda and influence their priorities. Thus, in theory, Smith possesses significant sway over the extent to which Democrats can back Jacobs’ proposed legislation limiting arms sales to the UAE. Indeed, ADI donated $1630 to Smith between September 2023 and February 2024.

As for the Republicans who influence the committee, ADI communicated with the Staff Director Vieson – whose importance has already been outlined – and his deputy. ADI also engaged with the offices of two Republican representatives on the committee: HASC chairman Mike Rogers and vice-chairman and Rob Wittman.

Rogers holds a highly influential position in the legislative process of amendments to the NDAA. He plays a key role in setting the committee’s agenda and influencing its policy focus. In addition, he has substantial power in deciding which amendments – such as those limiting arms sales to the UAE - can be considered. The vice-chairman – Wittman – is typically expected to support the chairman. ADI gave him $4,000 between September 2023 and July 2024.

The importance of Johnson and Scalise

Lobbying on the UAE’s behalf with regards to legislative amendments referencing the UAE, ADI also contacted House speaker Mike Johnson and Majority Leader Steve Scalise. With the two aforementioned Republican representatives playing significant roles in shaping NDAA amendments, ADI contributed a substantial amount to them: $10,500 shared between them from April 2023 to January 2024.

As the House Speaker, Johnson can, in theory, set the legislative agenda and decide which proposals may receive attention or are side-lined. He also has the power to determine the rules for how the NDAA is debated, amended and voted on. The Majority Leader also influences proposed NDAA amendments through their coordination with key committees, particularly the House Rules committee which sets the terms of debate for the NDAA on the House floor.

House Rules Committee

It is therefore no surprise that the ADI contacted the office of Republican representative Guy Reschenthaler on both 3 June and 10 June to discuss NDAA Amendments that reference the UAE. Unlike most of the others contacted, Reschenthaler sits on neither the HFAC or the HASC. However, Reschenthaler is the vice-chair of the House Rules committee (HRC).

The HRC can decide which amendments, such as those proposing limiting arms sales to the UAE, can be allowed for floor consideration. It can also impose rules for the debate, including on voting procedures. As such, it is a powerful gatekeeper for NDAA amendments. ADI have also contributed significant sums to members of the Rules Committee. Between April 2023 and September 2024, at least $4,875 was sent to Reschenthaler and Tom Cole, who chaired the committee until April 2024.

1.5 ECONOMIST LETTER

The registered documents also show how, on 9 September 2024, ADI registered material it distributed on behalf of the UAE’s embassy in the form of a letter to the Economist published on 5 September.

On 31 August, the Economist published an article on the war in Sudan that said “the UAE has the most influence on the war,” citing the UN’s suggestions that there is “credible” evidence that the UAE has armed the RSF. The Economist added that the UAE’s support for the RSF is “a product of personal relationships” with RSF leader Himedti, with the RSF’s vast network of businesses reportedly managed by a UAE-based advisor.

In addition, the UAE’s backing of the RSF was attributed to a “broader strategy” where the Emiratis are said to “want to build a network of clients across Africa in order to vanquish political Islam, to extend the UAE’s influence over the Red Sea and to pursue commercial ventures in everything from minerals to logistics to agriculture”. Even more damaging to the UAE’s reputation was the Economist quoting an Emirati government advisor saying: “if [the UAE] get their man in Khartoum, they think they can secure their access to food and farmland in perpetuity”.

Six days later, the Economist published a letter titled ‘The UAE responds’ that was attributed to the UAE’s assistant minister of foreign affairs for political affairs. It said the following: “your allegations are misdirected. The UAE is not providing weapons or any other support to the Rapid Support Forces”. The letter insisted that the UAE played a constructive role in peace talks for Sudan and stated the Emirati “committed to intensifying diplomatic efforts to protecting all civilians, especially women and children, from all forms of violence, including sexual violence”.

It is unclear whether ADI wrote the letter on the UAE’s behalf, or simply distributed it to those targeted for lobbying. This could become clearer towards the end of February 2025, when ADI will be required to file their next supplemental statement.

2. AKIN GUMP ET. AL

Akin Gump Strauss Hauer & Feld (hereby referred to as Akin) is the second-largest lobbying firm in Washington by revenue. As per its most recent Supplemental Statement on the FARA registry, the UAE Embassy is Akin’s most lucrative foreign government-linked client. While Akin receives the second-highest amount from the UAE embassy out of the five agreements assessed, it made the most in political contributions and registered the most activity and contacts to US politicians during the 2023/24 period covered. Indeed, Akin’s activity on the UAE’s behalf – and their contributions – increased after the turn of the year following a letter by 10 Democrat Congress reps calling for the UAE to stop supporting the RSF.

2.1 FINANCIAL

This sections covers the fees received by Akin from the UAE Embassy in Washington, followed by the former’s political contributions.

2.1.1 Fees

From March 2023 to May 2024, the UAE embassy in Washington paid $5,954,638 to law firm Akin. The scope of services offered by Akin as per their FARA registration include conducting outreach and advising the embassy on foreign policy and international trade issues including, but not limited to:

· Cooperation on bilateral military and security matters.

· The influence on U.S. politics by Mideast regional media outlets and other groups.

· U.S. Congressional matters (including relationship building, and monitoring, compiling information, and analyzing the potential and legal ramifications of legislation.

2.1.2 Contributions

Before taking a deep dive into Akin’s political contributions, we must stress that there is no indication of any illegality or that funds from the UAE were used to make these contributions. Our analysis of the data on Akin’s political contributions aims to show its financial influence in Washington. In the period under analysis, Akin received substantial amounts for services rendered from various foreign government clients including:

· Uzbekistan

· Palau

· Morocco

· Japan

· Marshall Islands

· Hong Kong

· Cambodia

With five firms hired to lobby on the UAE’s behalf making $1,040,384 in political contributions from 15 April 2023 to September 2024, 72.6% of this sum were Akin’s contributions of $756,070 until June 2024. 22% of that - $168,210 went to House Representatives and Senators that Akin contacted on the UAE’s behalf. That figure does not include $750 given on 28 June 2024 to Sara Jacobs, a Democrat House Representative pushing for US arms sales to the UAE to be halted amid accusations of its support for the RSF in Sudan.

The chart below arranges Akin’s political contributions from April 2023 to June 2024 by the most popular House committees to which representatives contacted on the UAE’s behalf were assigned. It must be emphasised that not all representatives who received contributions from Akin were contacted by the lobbying firm on the UAE’s behalf during that time period.

Akin contributed $119,250 split between 30 of the 41-member Ways and Means Committee that reviews government budgets. $45,150 was shared between 21 of the 59-member Armed Services Committee, with $42,025 split between 29 of the 51-member Foreign Affairs Committee. 26 of the 61-member Appropriations Committee shared $52,675.

2.2 PERIOD ONE (12 Jul-20 Dec 2023)

During the last six months of 2023, Akin’s lobbying on the UAE’s behalf primarily revolved around US-UAE relations and the 28th United Nations Climate Change Conference (COP28). Nonetheless, the final communication made was explicitly related to Sudan.

2.2.1 Targets

From July to December 2023, Akin made 105 contacts to US stakeholders on the UAE’s behalf, including US government officials at the Departments of Justice, Homeland Security, Commerce, Energy and the White House climate lead. Akin also contacted six Senators (3 Republican and 3 Democrat) and 26 House Representatives (23 Republican and 3 Democrat). From July to December, Akin also contributed at least $35,850 to Senators or House representatives contacted on the UAE’s behalf.

The most represented House committee out of those contacted was the Ways and Means with seven. Akin also met with five representatives assigned to Foreign Affairs, Armed Services, Energy and Commerce and Transport and Infrastructure committees.

2.2.2 Themes

41 of the 105 contacts were related to various matters of US-UAE relations including legal and trade cooperation. With Dubai hosting COP28 from 30 November to 13 December 2013, 30 contacts were related to that.

17 contacts were made with the purpose of discussing “foreign government funding for US universities and foreign government-owned media operations in the United States”, which hints at the UAE lobby’s awareness of rival influence campaigns in the US. 16 of the contacts were related to regional issues including the Houthis in Yemen and the Abraham Accords. Only one of Akin’s communications was directly related to Sudan.

2.2.3 Sudan letter

On 20 December 2023, Akin registered communication via email to Sophie Jones, the Democrat Staff Director of the House Subcommittee on Africa. The purpose was solely titled “Sudan Letter” without further expansion. This was likely to do with a letter dated a day earlier addressed to the UAE’s foreign minister calling for the country to end its support to the RSF.

Alongside arguing that the UAE’s support for the RSF adds to the risk of state collapse in Sudan “which is not in anyone’s interests,” the letter said that “members of Congress are paying attention to the UAE’s actions in Sudan…Support to the RSF…alienates the Sudanese people – who will not accept an RSF victory”.

It was signed by ten Democrat representatives, all of whom were assigned to relevant committees targeted by the UAE lobby. They were:

· The top signature on the letter was Sara Jacobs’, who is the Democrats leader on the HFAC’s subcommittee on Africa.

· Another two of the remaining three Democrats on the subcommittee also signed the letter: Colin Allred and Sheila Cherifilus-McCormick.

· A further four democrats on the HFAC signed the letter (Jason Crow, Dina Titus, Sydney Kamlager-Dove and Joaquin Castro).

The remaining three signatories were:

· James McGovern (Democrat leader on the Rules committee)

· Dan Kildee (serves on the Budget and Ways and Means committees)

· Barbara Lee (the Democrat leader on the State, Foreign Operations, and Related Programs subcommittee of the Appropriations committee).

As per Sophie Jones Twitter account, she has since gone on to cover foreign policy and Africa for Jacobs. Akin’s communication with her was the last registered for the period covering July to December. The next six-month reporting period saw a stark rise in contacts made on the UAE’s behalf amid growing scrutiny of its involvement in Sudan.

2.3 PERIOD TWO (12 Jan-27 Jun 2024)

Like ADI, Akin’s lobbying on the UAE’s behalf significantly increased from January to June 2024. Contacts made more than tripled from 105 to 327. Politicians (Senators and House representatives) contacted doubled from 32 to 65. Money spent on contacted politicians also increased from $35,850 to $66,305. The next section will look at who Akin target, and the themes of their outreach.

2.3.1 Targets

Akin communicated with ten government officials from the departments of Justice, Commerce and Homeland Security. There was also contact with staff at the Ways and Means, Oversight and Accountability and Commerce committees, as well as the staff director at the HFAC’s Middle-East and North Africa subcommittee.

Senators contacted rose from six to 27 (24 Republican, 3 Democrat). The most popular Senate committees among Senators contacted were the Armed Services, Commerce, Science and Technology and the Appropriations committees, all with eight Senators. The Senate Foreign Affairs committee had seven contacted, and the Environment and Agriculture committees had six each.

House Representatives contacted by Akin also rose from 26 to 38 (20 Republican, 18 Democrat). The HASC topped the list of committees of those contacted on the UAE’s behalf, with Akin communicating with 11 members. The Ways and Means committee had nine representatives contacted, the Appropriations had eight, and the Budget and HFAC had five each.

2.3.2 Themes

Regarding the purpose of Akin’s outreach, 57.8% of the 327 contacts – 189 - were related to meetings and visits. 126 of these were meeting requests to do with introducing new UAE diplomats or UAE-US relations broadly. There was also communication do with coordinating visits to the UAE for House Ways & Means committee staff. 16.8% of the communications were related to the UAE’s space programme, reflecting its growing importance in the Emirates’ diplomacy.

Regional security issues were the purpose of 39 contacts, with 18 of them covering Congress’ concerns about counterterrorism and the US Department of Justice’s enforcement of unregistered foreign government owned media in the US. The latter reflects the UAE lobby’s awareness of competing influence campaigns.

Only three contacts were related to “NDAA member amendments of interest to [Middle East and North Africa] region”, all of which were to the office of Republican Representative Andrew Ogles who is assigned to the House Financial Services Committee. This may hint at appealing to the US’ financial interests amid campaigns to block US arms sales to the UAE. While Ogles’ office was contacted on 28, six days after Jacobs’ proposed legislation, Akin’s other two communications were made on 11 March and 2 May.

3. FGS

Out of the five firms analysed in this report, FGS is the highest paid by the UAE. This figure is inflated by the fact that FGS renders its services to both the UAE embassy in Washington and the UAE’s Mission to the UN. However, while FGS’ FARA filing registered the firm’s regular communications with US House Representatives and Senators on the behalf of its other foreign government clients, its outreach for the UAE predominantly targeted media. FGS’ registered activity on the UAE’s behalf also increased from the end of 2023 into 2024. However, while Gaza and the Red Sea conflicts were prominent themes, Sudan was never explicitly mentioned in the assessed documents.

3.1 Finances

Commencing on 1 March 2024 and continuing until 31 December 2026, FGS Global will invoice the UAE Embassy in Washington $5,300,000 per year to be billed in 12 monthly instalments of $441,666.67. FGS Global also lobbies on behalf of the Permanent Mission of the UAE to the UN, to whom it paid $492,138 in December 2023. Indeed, the UAE mission to the UN is obliged to pay FGS $25,000 per month from March 2024 to February 2025.

FGS has registered receiving at least $6,754,353 from UAE government clients in the US from the outbreak of war in Sudan until its last FARA registration in September 2024, making it the highest-paid firm out of the five analysed in this report. FGS also ranks second-highest with regards to political contributions out of the five firms covered. From April 2023 to September 2024, FGS donated $168,620 to political campaigns and offices.

3.2 Scope of services

As per FGS’ agreement with the UAE Embassy, it is obliged to assist and support the Embassy “in the planning an [sic] ongoing implementation of a

comprehensive public diplomacy and communications program to sustain and enhance public awareness and understanding of the UAE among U.S. policymakers and opinion leaders”. This includes, but is not limited to:

· Provide messaging, editorial and content support as required for UAE Embassy communications.

· Design and conduct training sessions for Embassy diplomats and other Ministry of Foreign Affairs officials or staff.

· Identify and plan speaking forums, conferences, seminars, or briefings for UAE officials.

· Support UAE Embassy outreach and program development with third-party groups, such as business and trade associations, think tanks, non-governmental organizations, and cultural institutions.

3.3 End of 2023

During the six-month reporting period from August 2023 to February 2024, FGS registered 34 external contacts on behalf of the UAE embassy in Washington between August and December. The bulk of these were to media outlets. There were only two communications with House representatives (Scott Peters and John Curtis) which were to do with COP28.

FGS engaged government officials on the UAE’s behalf three times. The conflict in Gaza was discussed with an official at the US State Department, before COP28 was discussed with Commerce and State Department officials. COP28 was also covered during in-person meetings with two mayors in the states of New York and New Jersey.

Cultural and recreational matters were also a prevailing theme of FGS’ registered outreach on the UAE’s behalf during this period, reflecting their role in the UAE’s influence campaigns. For example, a potential partnership with the UAE embassy was discussed with the New York City Parks Department, as was an artist workshop by an Emirati ceramist with different museums affiliated to the Smithsonian Institute - the world’s largest museum, education and research complex.

FGS also engaged the mainstream media on the UAE’s behalf at least 19 times, although the documents provided little detail beyond the purpose of communication.

In August, there was contact with the Financial Times on UAE-US relations, Wall Street Journal on UAE economic policy and the New York Times on the UAE’s invitation to BRICS (an intergovernmental organisation considered an alternative to the G7 that includes Brazil, Russia, India, China and the UAE). US foreign policy and an unspecified interview request were also discussed with Bloomberg.

In September, FGS reported arranging an interview with Anwar Gargash, the diplomatic advisor to the UAE president, for NPR. Bloomberg were invited to a UN briefing, and interviews with UAE officials were covered with the New York Times and Wall Street Journal.

There was less registered media engagement from October to December. Axios was contacted with the purpose of media outreach in November and December. UAE investment in the US was discussed with Bloomberg, while the Gaza conflict was covered with the Washington Post. There was also an interview request from the New York Times.

As for the UAE’s mission to the UN, FGS only registered five communications on their behalf – all from September to November 2023. All were “regarding UN General Assembly interview”, and were with the New York Times, Politico and Axios.

3.4 2024

In the six-month reporting period ending September 2024, FGS’ registered no activity on behalf of the UAE’s mission to the UN. However, contacts on behalf of the UAE embassy more than tripled to 71, all from February to July.

The bulk of this was again to media outlets, with the exception of five contacts with the offices of mayors in New York and New Jersey regarding communications coordination and two ongoing discussions with the New York City Parks Department on a potential partnership.

24 out of the 71 contacts were to media outlet Semafor to discuss engaging with UAE officials, all in April and May. 18 of the contacts were registered as having the purpose of media outreach, which were to the following outlets: AP, Semafor, Axios, Bloomberg, Financial Times, NBC, ABC, Wall Street Journal, Reuters and the New York Times. All aforementioned communications occurred from 17 to 23 April. 8 of the contacts were regarding AI initiatives, and were with: Al-Monitor, Wall Street Journal, Financial Times and Bloomberg.

The remaining 14 of FGS’ media outreach on the UAE’s behalf covered the following: UAE-US defence cooperation and the Red Sea conflict with the Wall Street Journalist, Gaza aid and UAE-US relations with the Washington Post and the NATO summit with the Financial Times.

4. GILLILAND & MCKINNEY

From April 2023 to November 2024, the UAE embassy in Washington has paid Gilliland & McKinney International Counsellors (G&M) $407,200. This section will cover how the UAE’s agreement with the firm has increased in scope and funding since the outbreak of war in Sudan.

4.1 G&M in 2023

For the six-month reporting period registered by G&M ending 25 May 2023, it was paid $16,245 for “policy and strategic advice and counsel with respect to U.S. foreign and economic policy, including with respect to bilateral economic relations between the United States and the United Arab Emirates and joint agricultural research initiatives”.

Then, for the next six-month reporting period – ending 20 November 2023 – G&M ‘s earning were more than tripled to $60,480. In June and July, it registered communication with Senior Staff at the House Ways and Means subcommittee on trade and Senate finance committee on US-UAE economic relations, and the office of Governor Josh Shapiro on meeting the UAE ambassador.

4.2 G&M in 2023

G&M increased its engagements with during the six-month reporting period after that which ended on 29 May 2024. Its earnings almost doubled: reaching $119,250. Between 6 and 29 February 2024, G&M communicated with the offices of 10 Democrat representatives to discuss “US-UAE trade relationship and regional security issues”.

The most represented committee out of those they met was the HASC, with G&M meeting three (Marc Veasey, Mikie Sherrill and Ruben Gallego). G&M also met with two members of the Appropriations Committee which oversees federal funding allocations and two of the Ways and Means Committee that reviews government budgets.

For the next six-month reporting period – ending 13 November 2024 – G&M’s earning increased to $226,120 although the documents did not reveal any registered activity. However, scope of their agreement expanded to: “[providing] policy, strategic, and legal advice and counsel regarding […] U.S. foreign policy, foreign investment, and international trade issues; sanctions and export control compliance and programs; cooperation on bilateral military, security, and legal matters; assistance to refugees and other international humanitarian and development aid; influence by Mideast regional media outlets and other groups on U.S. politics; cybersecurity; and U.S. congressional matters”.

Since the outbreak of war in Sudan until October 2024, G&M paid $8,790 in political contributions. Of this amount, $500 went to a politician who was contacted on the UAE’s behalf: Ruben Gallego.

5. BULLPEN

Between April 2023 and June 2024, Bullpen Strategy Group received $487,500 from the UAE Embassy in Washington, which was sent in $32,500 monthly instalments. Out of the five firms hired by the UAE to lobby on their behalf, Bullpen received the fourth most in payments. This section will cover Bullpen’s controversial history, followed by the work they do for the UAE embassy.

5.1 Bullpen’s history

Bullpen’s relationship with the UAE embassy began as early as late 2017, during the heat of the UAE’s diplomatic dispute with Qatar. Back then, the UAE’s contract was signed with Definers Corp – a right-leaning opposition research firm founded by Republican Party political operatives that specialised in strategic communication to negatively influence the public image of its client’s rivals.

However, in 2018, Definers was embroiled in a controversy to do with its work for Facebook, resulting in the social media giant cutting ties with the firm. Then, in 2019, Definers Corp co-founder Joe Pounder, a former senior advisor for Senator Marco Rubio’s presidential campaign, bought out Definers and rebranded it as Bullpen Strategy Group.

5.2 Bullpen’s work

As per Bullpen’s last registration, they offer the UAE embassy “strategic communications support and guidance in furtherance of the interests of the Embassy of the United Arab Emirates, with an emphasis on strengthening bilateral relations and regional security of the United Arab Emirates”. The document reveals a particular reference to “issues relating to [the UAE’s] termination of relations with Qatar and accuracy and transparency of Qatar government-owned media”.

But despite the $32,500 monthly payments sent to Bullpen, they are the most discreet out of the five analysed firms when it comes to registering their activity on the UAE’s behalf. This can perhaps be explained by the focus of its predecessor -Definers Corp - on media monitoring as opposed to outreach to politicians. Such work would be more internal than than public-facing.

Activity on the UAE’s behalf registered by Bullpen from 15 April and July 2023 only included contact with the Washington Examiner in May on bilateral relations. From July to December 2023, Bullpen only registered communication with seven US-based media outlets: Associated Press, New York Times, New York Magazine, Daily Wire, Wall Street Journal, Politico and Washington Free Beacon. Again, the purpose was listed as “bilateral relations” without further expansion. During that period, Bullpen still received their monthly $32,500 in August and September 2023 despite no registered activity in those months.

Then, for the period covering January to June 2024, Bullpen only registered communication with five media outlets (Associated Press, Washington Free Beacon, Semafor, New York Times, New York Magazine and Daily Wire). Again, the stated purposed was “bilateral relations” without further expansion. Furthermore, there was no registered activity for the months in the months of March, April and May – but Bullpen still received their monthly $32,500.