Department of Justice Should Investigate Apparent Violations of FARA Rules
(Washington D.C., August 30, 2023) – Former Legislative Assistant Rashid Hallaway and his lobbying firm Hobart Hallaway & Quayle Ventures (HHQ) are sportswashing the Saudi government's human rights abuses by lobbying for Saudi government-owned LIV Golf, said Democracy for the Arab World Now (DAWN) in a new report released today.
DAWN's findings also show that Hallaway and HHQ appear to have violated U.S. laws by failing to register their work for LIV Golf with the U.S. Department of Justice (DOJ) as lobbyists for a foreign government, as required by the Foreign Agents Registration Act (FARA), and to acknowledge serving the interests of a foreign entity in HHQ's Lobbying Disclosure Act (LDA) filings with the U.S. Congress.
"Rashid Hallaway and his partners at HHQ have chosen to contribute to and benefit from the Saudi government's gross human rights abuses by lobbying for the Saudi Public Investment Fund – owned LIV Golf," said Sarah Leah Whitson, DAWN's Executive Director. "They have misled Congress, the Biden administration, and the American public by not acknowledging the foreign interests they serve and reporting on their activities benefiting those foreign interests, as required by law."
Rashid Hallaway, Ben Quayle, and David Natonski of HHQ Ventures have registered as lobbyists for LIV Golf, Inc. pursuant to the Lobbying Disclosure Act (LDA) on August 1, 2022, but did not register them as foreign agents under FARA. According to its most recent LDA filing (Quarter 1, 2023), HHQ Ventures earns $140,000 per quarter from LIV Golf, paid for by the Saudi government's Public Investment Fund (PIF), where Crown Prince Mohamed bin Salman (MBS) is Chairman. Mr. Hallaway is a former Legislative Assistant for U.S. Senator Evan Bayh; Mr. Quayle is a former Member of the House of Representatives for Arizona's third district and son of the 44th Vice President Dan Quayle; and Mr. Natonski is the former Chief of Staff for Representatives Greg Murphy (NC), Denver Riggleman (VA), Kevin Yoder (KS), Trey Radel (IL), among other staff positions.
Rashid Hallaway has leveraged his lobbying firm and position as a former Legislative Assistant to promote Saudi-owned LIV Golf's interests in the U.S., omitted crucial information about Saudi Arabia's unlawful, dangerous, and destabilizing abuses, and helped to sportswash Saudi Arabia's human rights record. LIV Golf itself is widely perceived to be non-viable commercially and was created solely to take over global golf either by competing with or acquiring PGA Tours. By acquiring these global assets, the Saudi government and its agents, like HHQ, seek to nudge public opinion in the government's favor, divert attention from its abuses, and influence players, business persons, and politicians to represent it sympathetically and stay silent about its abuses.
HHQ appears to have breached its business human rights obligations by contributing to and benefiting from Saudi Arabia's human rights abuses. Under the UN Guiding Principles on Business and Human Rights, businesses have a responsibility to "avoid causing or contributing to adverse human rights impacts through their own activities" as well as "to prevent or mitigate adverse human rights impacts that are directly linked to their operations, products or services by their business relationships, even if they have not contributed to those impacts." Lobbying on behalf of governments, agencies, government investment funds, or officials like those in Saudi Arabia responsible for grave crimes, including war crimes, torture, arbitrary arrests, and extrajudicial killings, effectively contributes to such abuses.
"International standards and American laws exist to avoid exactly this type of situation where powerful or wealthy entities like the Saudi PIF can buy their way out of murder through the services of lobbyists like HHQ," said Sevag Kechichian, a Senior Researcher with DAWN. "HHQ may think its work for Saudi Arabia is masked behind the fig leaf of LIV Golf, but we need to see right through their smoke and mirrors."
Hallaway and HHQ also appear to have violated U.S. laws by failing to register with the DOJ as lobbyists for a foreign government as required by FARA. The Saudi government owns and controls the PIF, which is chaired by the Saudi Prime Minister and Crown Prince MBS. FARA requires lobbyists to report on activities that serve foreign interests. And while it exempts LDA-registered lobbyists from FARA registration, this is only if the lobbying activities are not on behalf of a foreign government or the foreign government is not the primary beneficiary of the lobbying activities. Given that the Saudi government owns and controls LIV Golf, HHQ's lobbying for LIV Golf in fact, serves the interests of the Saudi government.
HHQ also appears to have misrepresented its client LIV Golf in its LDA filings. While it registered as a lobbyist with under LDA, it answered "no" to the question (Item #19) as to whether a foreign party has an interest in its lobbying activities, despite stating that PIF owns 100% of LIV Golf in the same forms. HHQ's LDA forms also fail to mention that LIV Golf, Inc. is itself a foreign company, as provided by the LIV Golf's UK registration forms and the State of Florida Foreign Corporation registration form.
"In this complex world of global politics and business, transparency and accountability are vital. Our democracy depends on our ability to understand who is influencing our policymakers and their true motives," said Raed Jarrar, DAWN's Advocacy Director. "Rashid Hallaway and HHQ's lobbying activities on behalf of Saudi-owned LIV Golf not only undermine these democratic tenets but also provide a smokescreen for the Saudi government's severe human rights violations. This case is not just about lobbying or golf – it is about preserving the sanctity of our democracy."
Saudi Arabia and MBS have been aggressively using sportswashing to divert attention from MBS's personal involvement in the country's gross human rights abuses, including the murder of Jamal Khashoggi, without regard to costs or profit. Establishing LIV Golf in 2021 by the Saudi PIF is part of this strategy, which also include sits purchase of the English Premier League's Newcastle United Football Club, soccer superstars such as Cristiano Ronaldo and Karim Benzema, Formula 1 sponsorships, World Wrestling Entertainment (WWE) exclusive events and rights, eSports and many other global sporting and entertainment assets.
DAWN urges the Department of Justice and other pertinent U.S. authorities to thoroughly investigate HHQ's apparent violations of FARA and the LDA. If these infringements are confirmed, the DoJ should require HHQ to register under FARA and impose appropriate penalties. Upholding the principle of accountability is crucial, and it necessitates that all entities, regardless of their stature, comply with the same legal standards.
DAWN calls on HHQ to drop their contract with the LIV Golf, conduct a thorough review of all their clients, and cease representation of abusive clients such as assets owned by the PIF and the Saudi government, including LIV Golf. HHQ should comply with the UN Guiding Principles on Business and Human Rights to avoid causing or contributing to adverse human rights impacts through their own activities and to prevent or mitigate adverse human rights impacts that are directly linked to their operations or relationships, even if they have not contributed to those impacts.
DAWN urges Congress to reintroduce legislation that advances our goals, including Fighting Foreign Influence Act and the Anti-Corruption and Public Integrity Act.
DAWN also urges members of Congress to refuse to meet with lobbyists working for abusive governments and their affiliates and companies, like HHQ, 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.
