From 2009 to 2014, financier Low Taek Jho allegedly carried out a plot to embezzle billions of dollars from the Malaysian government in one of the largest money-laundering operations in history. Following revelations of this apparent conspiracy, Low has been an international fugitive, and both Malaysian and American authorities have sought to seize his assets.

Since then, Low, commonly known as “Jho Low,” has reportedly funneled millions of dollars into the United States in an attempt to influence the Justice Department’s investigation into his activities. Due to restrictions on his access to U.S. and foreign banks, Low has, until now, apparently relied on shell corporations and straw donors to transfer his wealth into the country, avoiding making any direct payments to U.S. entities.

However, according to a CREW analysis of new documents filed under the Foreign Agents Registration Act (FARA), Low’s practices may recently have changed in a more troubling way. Contractual language in recent FARA filings appears to suggest that Low has made at least one direct payment to a law firm hired to represent him—and that future payments from Jho Low to U.S. entities working on his behalf may be expected as well.

In November of last year, Low was indicted by the Justice Department for allegedly orchestrating a conspiracy to embezzle $4.5 billion from 1Malaysia Development Berhad (1MDB), a Malaysian government development fund. Just prior to his indictment, Low hired two international law firms, Schillings International and Kobre & Kim, to represent him in the United States. The two firms registered as foreign agents of Low under FARA, requiring them to disclose any payments received from Low for their services.

Both Schillings and Kobre & Kim were careful at the time to specify that they had not received any payments from Low himself; instead, both firms stated in their FARA registrations that they had received funds for their services from unnamed parties “on behalf of” Low. This disclaimer may have been due to the questionable legality of Low’s funds.

New FARA documents filed last month suggest that this arrangement may have changed, with Low now seemingly paying his U.S. representatives.

On March 6, the PR firms Levick Strategic Communications and Reevemark LLC registered as foreign agents of Low in connection with work done for Kobre & Kim on his behalf. Kobre & Kim’s October 31, 2018 FARA registration statement stated that the law firm “has not received funds from [Jho Low].” Levick’s contract with Kobre & Kim, however, states that while Kobre & Kim “may settle invoices on behalf of [Low],” Low “is ultimately liable for all fees and expenses related to this engagement,” and that Kobre & Kim “will only be responsible for advancing LEVICK’s fees and expenses to the extent that [Kobre & Kim has] funds available from [Jho Low].”

Reevemark’s contract with Kobre & Kim contains nearly identical language.

In other words, the contracts appear to provide that Low is responsible for the two public relations firms’ fees and expenses, which would only get paid through Kobre & Kim if Low had made funds for those payments available to the law firm.

Both contracts suggest the public relations firms have been paid or strongly anticipate receiving payment. Levick’s contract lists a retainer fee of $50,000 for work done between February 21 and March 7, 2019. If Kobre & Kim has paid Levick for this presumably completed work, then the contract’s language stating that Kobre & Kim would only be paying Levick to the extent that it had received funds from Low suggests that Low has provided at least $50,000 to the law firm.

The language in Reevemark’s contract similarly suggests that Kobre & Kim has received or expects to receive funds directly from Low in order to pay Reevemark’s fees. That contract, dated March 4, 2019, says the $175,000 payment for Reevemark’s work between February 15 and March 31, 2019 is “payable immediately,” indicating it may have already been paid. The contract then sets Reevemark’s compensation at $125,000 per month.

Additionally, while it is not fully clear, both contracts state that Low is “ultimately liable” for all fees and expenses related to its hiring by Kobre & Kim, implying that Low may be expected to pay the PR firms directly in the future if Kobre & Kim is unable to pay.

These contracts thus appear to indicate that Low may still be directing money into the United States in order to pay for Reevemark and Levick’s fees and expenses. If true, this practice has disturbing implications, given Low’s alleged record of embezzlement and money laundering; last year, Low was reportedly suspected by the DOJ to have laundered money into the country in order to pay legal fees.

Kobre & Kim’s arrangements with Levick and Reevemark are highly unusual. Based on these contracts alone, it’s impossible to establish with full certainty what sort of financial relationship exists between Low, Kobre & Kim, and the two PR firms. Nevertheless, these documents suggest that Low may have made previously unreported direct payments to his lawyers in the United States. These arrangements demand a fuller explanation; Kobre & Kim will have a chance to provide more detail in its next FARA supplemental statement, which is due to be filed at the end of April.

Recent news reports have revealed that the Justice Department is investigating whether Low made an illegal contribution to a pro-Trump political committee. In light of these continuing revelations, the work of Low’s legal and PR teams is unlikely to end anytime soon.

It is crucial that the American government and public be kept apprised of Low’s financial relationships with his agents in the United States, and that the details of his legal and public representation be clearly and unambiguously disclosed. As long as the law firms he has retained refuse to disclose the sources of their funding, this will not be the case—and these new FARA documents only contribute to the confusion.

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