Department of Justice Should Investigate DAWN's Complaint Regarding Emanuel's Failure to Register as a Foreign Agent
(Washington D.C., July 25, 2023) – Adam Emanuel, a lobbyist for over 20 years for a number of Israeli weapons manufacturers and technology companies, should register as a foreign agent because of his work as an unregistered foreign agent on behalf of Israel Aerospace Industries (IAI), an Israeli state-owned weapons manufacturer, said Democracy for the Arab World Now (DAWN) in a new investigation released today.
"Despite the well-documented human rights abuses committed by successive Israeli governments using IAI weapons, Mr. Emanuel has misled American officials by failing to disclose the true nature of the interests he represents," said Adam Shapiro, Director of Israel-Palestine Advocacy at DAWN. "Mr. Emanuel has avoided registering as a foreign agent for over 20 years, despite promoting Israel's political interests to Congress, including securing taxpayer funds for sending missiles to Israel."
Emanuel is a registered lobbyist for Israel Aerospace Industries NA (IAI NA), the U.S. subsidiary of IAI, but has publicly acknowledged his lobbying for the Arrow Missile System, a Congressionally-funded missile program covered under the U.S. military assistance program to Israel and thus a non-commercial interest of the Israeli government. Lobbying for the Arrow Missile System, which is manufactured by IAI in Israel, directly promotes the political interests of the Israeli government – the owner of IAI and IAI NA – and as such should be a Foreign Agent Registration Act (FARA)-registered activity, as is normal practice for those representing a foreign principal. Mr. Emanuel has not registered with FARA in over 20 years in his representation of IAI NA and IAI (formerly named Israel Aircraft Industries, Ltd.)
Emanuel and his firm, Emanuel & Associates, are registered with the Lobbying Disclosure Act (LDA). However, neither are registered with the FARA Unit at the Department of Justice (DOJ). In the FARA statute, there is an exemption for LDA-registered lobbyists, but it is not applicable if the agent works on behalf of a foreign government. By lobbying for the Arrow Missile System, which he asserts on his LDA forms, Emanuel is working to advance the interests of the Israeli government.
DAWN has submitted a referral to the FARA Unit, the third referral in a year in which lobbyists for Israeli government-owned or -controlled companies have failed to register or register properly with FARA, thus obscuring the true nature of representation of Israeli government interests in the United States.
In addition, the work of Emanuel & Associates (of which Emanuel is the only listed lobbyist) on behalf of an Israeli weapons manufacturer breaches its human rights responsibilities under the UN Guiding Principles on Business and Human Rights by contributing to, and benefiting from, human rights abuses perpetrated by IAI. Lobbying on behalf of governments, agencies, officials, or companies responsible for serious human rights abuses, while misrepresenting or omitting information about their abuses of international human rights law or violations of international humanitarian law, or obtaining, sustaining, or expanding military, political, or economic support for them, effectively contributes to, and benefits from, such abuses.
IAI manufactures drones and other weapons systems that have regularly been used to bomb the civilian population of Gaza. In one of the first reports documenting the use of drones, Human Rights Watch noted the Israeli military's use of IAI's Heron drone and its payload of Spike missiles as one of two primary culprits for the killing of civilians in Gaza in the 2008-2009 Operation Cast Lead. Since then, IAI drones have been consistently deployed against Gaza.
Israel has deployed the HeronTP drone as part of its indiscriminate attacks against Gaza since 'Operation Cast Lead' in 2008. According to the 2014 report, "Sleepless in Gaza," commissioned by the Rosa Luxemburg Foundation, which documented the impact of Israeli drone attacks during 'Operation Cast Lead' (December 2008 to January 2009), "it is estimated that a total of 42 drone attacks were launched which killed 87 civilians. Of these, 29 were children. Some 73 others were wounded directly from such attacks." In the November 2012 "Operation Pillar of Defense: assault on Gaza, "around two-thirds of those killed by drone strikes (24 of 36), were civilians."
In May 2021, during the "Operation Guardian of the Walls" assault, Israeli airstrikes killed 67 Palestinian children and at least 129 civilians overall, which were enabled by IAI Heron drones. In the August 2022 "Operation Breaking Dawn" assault, Israeli officials claimed that "drones conducted more than 2,000 hours of flight time in some 100 sorties." In 66 hours, 49 people were killed in Gaza, among them 17 children, with drone attacks, including by IAI's HeronTP drones, accounting for the majority of the casualties. Israel's apparent indiscriminate and/or disproportionate attacks on Gaza with its aerial forces, including drones, constitute violations of international humanitarian law (IHL).
DAWN previously found that lobbyists for NSO Group, an Israeli spyware company and maker of Pegasus spyware, had failed to disclose the control of the company by the Israeli government. Though registered as foreign agents under FARA, the NSO Group lobbyists were misleading or intentionally deceiving the U.S. government and Congress by omitting required information under the FARA statute. On July 20, 2022 DAWN filed a referral with the Department of Justice FARA Unit detailing the violations by these four lobbyists and their firms – Steve Rabinowitz (Bluelight Strategies), Timothy Dickinson (Paul Hastings LLP), David Tamasi (Chartwell Strategy Group) and Brian E. Finch (Pillsbury Winthrop Shaw Pittman LLP) – and calling for punitive measures against them per the statute
"DAWN is uncovering a pattern whereby Israeli companies owned or controlled by the Israeli government and involved with gross violations of human rights are being represented in the United States by lobbyists who not only financially benefit and contribute to the abuses by securing military support for Israel, but also fail to meet legal registration and transparency standards," Shapiro added.
DAWN urges the Department of Justice FARA Unit to review the evidence submitted in its referral and impose the requisite penalties on Emanuel for his decades of misrepresenting his client and misleading the U.S. government and American people.
DAWN also urges Congress to promptly enact the For the People Act, which prohibits lobbyists from accepting compensation from foreign governments engaged in gross violations of human rights and makes other much-needed FARA reforms, and the Fighting Foreign Influence Act, which bans former members of Congress and senior political appointees from working as lobbyists for foreign countries and introduces important transparency measures requiring think tanks and other organizations to declare foreign funding. DAWN has called on members of Congress to refuse to meet with lobbyists working for abusive governments and their affiliates and companies, such as IAI NA, and to pledge not to work for such governments or their agents on leaving office.
DAWN's Lobbyist Hall of Shame will continue to expose American lobbyists—including lawyers, political operatives, former elected representatives and government officials—who are working as agents for abusive Middle East governments to garner U.S. government support, including military aid, weapons sales, and diplomatic protection. DAWN's complete set of recommendations to lobbyists and the U.S. Congress are available here.
