On Friday, September 14, 2018, former Trump campaign chairman Paul Manafort pleaded guilty to a superseding criminal information filed by the special counsel Robert Mueller and agreed to cooperate with his investigation into the 2016 election.
The document states that Manafort, along with Richard W. Gates, Konstantin Kilmnik, and others, conspired to act and acted as foreign agents of the Ukrainian government, as well as Victor Yanukovych’s political party, the Party of Regions, and its successor. As a result of his work on behalf of the Ukrainian government, Manafort allegedly generated over 60 million dollars, which he then funneled through various foreign entities in an attempt to obfuscate the source of the funds. Manafort did not register his activities or fees under the Foreign Agents Registration Act (FARA), as was required. Instead, when federal investigators inquired about his activities in 2016, he “responded with a series of false and misleading statements.”
Manafort pleaded guilty to conspiracy to conduct money laundering to unregistered lobbying and conspiracy to obstruct justice arising from his efforts to tamper with witnesses in his case. The prosecution dismissed five other counts.
The criminal information provides new details about the diverse ways in which Manafort and his co-conspirators tried to surreptitiously lobby the U.S. government and influence U.S. public opinion about Ukraine.
Prior to his guilty plea, Andrew Weissman, counsel for the special counsel, set forth in detail Manafort’s criminal conduct, including a 10-year scheme to act as an unregistered agent of a foreign government, concealing millions of dollars he earned from that work, and then after he was indicted, trying to tamper with witnesses in the case. 
After many months of litigation, Manafort finally accepted a plea agreement and agreed to cooperation in return for reduced charges.
Manafort is the fifth person connected to Mr. Trump to plead guilty to criminal charges. The others include his former personal lawyer Michael Cohen, his first national security adviser Michel Flynn, former campaign foreign policy adviser George Papadopoulos, and Manafort’s former business partner, Rick Gates, who also worked on the 2016 campaign.
Manafort faces up to 10 years in prison on the two charges and another 8 to 10 on a conviction in Virginia in August on tax and bank fraud charges. Depending on the extent of his cooperation and the extent prosecutors advise the court of his value of his assistance, he will receive a reduction under Section 5k1.1 of the United States Sentencing Guidelines.
In terms of the scope of his potential cooperation, they include his participation in the 2016 Trump Tower meeting with Russians offering to provide dirt on Hillary Clinton, whether Trump kew about that meeting, the 80-plus contacts between the Trump campaign and other associates and Russia-connection individuals, whether the Trump campaign knew about alleged Russian hacking of Democrats, the campaigns possible collaboration with WikiLeaks, the significance of Manafort’s other ties to Russia with respect to the Trump campaign and the amendment of the Republican National Committee platform on arming Ukraine. In addition, Manafort may be questioned on obstruction of justice by the president, including any pardon negotiations between the president’s personal lawyers and Manafort’s lawyers and whether any of these discussions could be construed as offering a pardon in exchange for Manafort’s silence.
The prosecution and plea demonstrates a greater willingness on the part of the U.S. government to actively prosecute violations of FARA. While FARA has existed since 1938, it has been enforced loosely, and for some periods, not at all, since its enactment. The plea indicates continued success by the special counsel in obtaining convictions as well as cooperation from insiders in the Trump campaign.
The enhanced scrutiny of FARA is illustrated by thte continuing investigations by prosecutors in the Southern District of New York of Gregory Criag, who on behalf of Skadden Arbs, worked for Manafort on the Ukrainian government matters. Prosecutors are also investigating lobbyists Vin Weber and Tony Podesta for their work on the same matter. Mueller transferred those cases to the U.S. Attorney for the Southern District of New York. The lobbying firms allegedly received more than $1 million each to work on behalf of Ukraine. They registered under the Lobbying Disclosure Act, but not under FARA. The prosecutions of Manafort and others illustrate the tougher enforcement approach with respect to FARA.
 United States v. Paul J. Manafort, Jr., U.S. District Court D.C., Superseding Criminal Information, Criminal No. 17-201-1 (ABJ) S-1). For a copy of the superseding criminal information see Zarine Kharazian, Mueller Files Superseding Information against Paul Manafort https://ielrblog.com/index.php/2018/09/14/mueller-files-superseding-criminal-information-against-paul-manafort.
 Nathan Layne and Jonathan Landay, Reuters, In plea deal, Manafort agrees to co-operate in Russia probe, Globe and Mail, Sept. 15, 2018, at A4, col. 1.
 Spencer S. Hsu, Devlin Barrett and Justin Jovenal, Manafort will cooperate with Mueller as part of guilty plea, prosecutor says, Wash. Post, Sept. 14, 2018.
 Noah Bookbinder, Barry Berke and Norman Eisen, Manafort Folded. Now What?, N.Y. Times, Sept. 14, 2018; Amber Phillips, Paul Manafort strikes plea deal with special counsel Robert Mueller, Wash. Post, Sept. 14, 2018.
 Tom Hamburger, Obama White House counsel Criag is under scrutiny by N.Y. prosecutors, Wash. Post, Sept. 24, 2018, at A8, col. 1.