- A letter to investors of Fraud Guarantee
offers new clues about the work
that Rudy Giuliani was hired to do for the company in 2018.
Fraud Guarantee, a purported fraud insurance company,
was the brainchild of Lev Parnas and David Correia,
two men who were charged in October
in an alleged scheme to make illegal campaign contributions.
Both have pleaded not guilty.
The Fraud Guarantee letter, dated September 12th, 2018,
said the company expected to pay Giuliani Partners
between $1 and $2 million in consulting fees
for the first year as well as provide Giuliani
with single digit equity participation.
In return, the letter said Giuliani
was going to help the company
as it tried to closely mirror the LifeLock model.
- I represent LifeLock, so take it for where it comes from.
I work for them, I'm an advisor.
Everybody should have something like LifeLock.
Everybody should have identity protection.
- LifeLock is an identity theft protection company
that Giuliani had previously promoted
and provided strategic counsel for.
The company ran into expensive regulatory issues
that Fraud Guarantee sought to avoid.
Fortunately, due to our pending relationship
with Giuliani Partners, we will be given the entire road map
and structure to proactively prevent such compliance issues,
the letter said.
Giuliani Partners will also help open doors
to larger institutional clients
by working in a business development capacity.
The letter goes on to say that Giuliani and his team
believed that Fraud Guarantee's ingenious products
would be well received in the investment
and lending communities.
Soon after the letter was sent,
Giuliani, who was President Trump's personal attorney,
was paid half a million dollars for his work
for Fraud Guarantee.
The letter has been handed over as evidence
and federal prosecutors in New York
are looking into Fraud Guarantee
as part of their investigation into the business
and political activities of Giuliani, Parnas,
and their associates, according to people
familiar with the probe.
Giuliani did not respond to questions
about his work for Fraud Guarantee,
but he said in a text message
that he has not heard from prosecutors.
He has not been accused of any crimes
and he has denied wrongdoing.
A spokesman for the US Attorney's office in Manhattan
declined to comment, and lawyers for Parnas and Correia
did not respond to a request for comment.
In a statement, Norton LifeLock said Giuliani's involvement
with the company ended several years ago
before an acquisition and that the company
doesn't have any information
about strategic advice Giuliani may have provided
to LifeLock's previous leadership.
The investor letter was provided to the Journal
by a man who said he invested in Fraud Guarantee
after Parnas told him he could do him a favor.
Claiming to have a relationship with then-candidate Trump,
Parnas allegedly said he could promote this painting
and its concept for a Middle East peace platform
to Trump himself.
It was commissioned by the investor
and portrayed his idea to construct
a third temple over Jerusalem.
The artist, who was present at a meeting with Parnas,
confirmed the investor's account.
President Trump has denied knowing Parnas
and his associates.
The investor doesn't know if Parnas ever showed Trump
the development idea depicted in the painting.
He said he'd like to recover the $250,000
he invested in Fraud Guarantee,
and after receiving a subpoena in recent weeks,
he said he's cooperating with prosecutors.
Shortly after the Fraud Guarantee
investor letter was sent out,
Parnas began flying across the country,
attending political events with Giuliani.
The men flew on a private jet
tied to a company owned by Trump donor Andy Beal
according to flight records and documents
reviewed by The Wall Street Journal.
Beal, who donated $2 million to America First Action,
a Trump-supported super PAC that federal subpoenas
have sought information about
in connection to the same investigation,
said in a text message: I simply have no comment
on whatever it is you seek to find.
A spokeswoman for America First Action
said the organization reached out
and offered to cooperate with prosecutors
and has not received a subpoena.
She declined to comment on Beal.
During his blitz with Giuliani,
Parnas rubbed elbows with prominent Republicans,
including former Florida Attorney General Pam Bondi,
who is now advising the White House
in its impeachment defense strategy.
Both the White House and Bondi
did not respond to a request for comment.
Parnas would go on to help Giuliani
in is efforts to get Ukraine
to investigate Democrat Joe Biden,
an effort that is now at the center
of impeachment proceedings in Washington.