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Legal Controversies Concerning Azerbaijan’s Lobbying in the US

June 18,2025 19:30

The Armenian Mirror-Spectator

by Suren Sargsyan

One of the tools for influencing political decision-makers and their policies in the USA is lobbying. This tool is used by both domestic actors and foreign governments, which hire lobbying organizations officially registered in the United States to promote their own interests. There are two main types of lobbying here – ethnic and professional. Professional lobbying implies hiring a professional lobbying organization, which acts on behalf of the foreign actor to promote its interests. In contrast, ethnic lobbying is exercised through American lobbying groups of various ethnic backgrounds. Jewish, Armenian and Greek lobbying groups are prominent examples.

US legislation requires public disclosure of agents acting on behalf of a foreign government. Hence, the data on foreign governments’ expenditures to buy influence in the USA is publicly available information.

The government of Azerbaijan has been using the services of professional lobbying organizations for years, and has spent millions of dollars for that purpose. Despite its attempts to hide some of its spending, bypassing US law, there is still a significant amount of public information which discloses the amount of money spent along with the goals the Azerbaijani government pursues. Throughout the years, Azerbaijani target areas for lobbying have not changed.

These goals are being consistently reflected in the contracts between the Azerbaijani government and the US lobbying firms and include but are not limited to anti-Armenian propaganda. They make use of Prime Minister Nikol Pashinyan’s speeches supporting Azerbaijani political discourse; constant statements on Armenia’s strong ties with Iran and Russia (adversaries of the US) and Azerbaijan’s strong ties with Israel, in order to show that Armenia cannot be a reliable ally for the US. They instead attempt to create the image of Azerbaijan as a tolerant multicultural state, and advocate for the continual waiver of Section 907 of the Freedom Support Act, which prohibits direct aid to the Azerbaijani government. Also, roundtable briefings and discussions are organized with the ambassador of Azerbaijan with the help of these lobbying organizations in which Congressional staffers and important members of the administration are invited to participate.

There are a few lobbying organizations hired by Azerbaijan in recent years that are worth investigating, including Skyline Capital LLC (with an agreement with the Embassy of the Republic of Azerbaijan), the Friedlander Consulting Group LLC (with an agreement with the Foreign Ministry of Azerbaijan),  and Teneo Strategy LLC (with an agreement with the COP29 Azerbaijan Operations Company).

The agreement between Skyline Capital LLC and the Embassy of the Republic of Azerbaijan to the United States of America is dated January 1, 2025 and expires on December 31, 2025. The organization is supposed to “deepen relationships between the Embassy and US Congressional and Executive leadership; facilitate and coordinate official Congressional Delegation (CODEL) and Congressional Staff Delegation (STAFFDEL) visits to Azerbaijan; work in a bipartisan fashion within the House and Senate, specifically targeting Members and staff who serve on the Foreign Affairs/Relations Committees, the Appropriations on State and Foreign Operations Subcommittees, the Armed Services Committees and the Rules Committees to identify potential opportunities for engagement between the U.S. and Azerbaijan; reinvigorate and expand the Congressional Azerbaijan Caucus; identifying potential champions for stronger partnership with Azerbaijan in both the House and the Senate and actively involving them in advancing the US – Azerbaijan partnership; [and] facilitate trade missions and economic engagement between Azerbaijan and the US.”

According to the agreement the organization is to be paid $50,000 a month, totalling $600,000 for the whole period.  This is an extension of the original agreement commencing on June 5, 2024 that expired on December 5, 2025. The monthly pay was still $50,000.

The agreement with the second organization, the Friedlander Consulting Group LLC, expired some months ago (at least for now there is no public information on the renewal). The agreement was in force from February 20, 2024 and expired on February 19, 2025. The monthly fee for the services of the company was $41,666.00 ($499,992 for twelve months). The company was hired to “implement a multi-faceted advocacy effort, media outreach and provide lobbying services to assist Azerbaijan to develop Azerbaijani-United States relations.”

However, the largest Azerbaijani lobbying deals in the US recently were for the campaign to hold the 29th United Nations Climate Change Conference (COP29) in Azerbaijan, and for the subsequent organization and large-scale coverage of the event in the US. In terms of money, Azerbaijan spent more than 5 million US dollars on the preparation, implementation and subsequent coverage of the event from April 2024 to November 2024. Contracts were signed between the COP29 Azerbaijan Operations Company and the US lobbying organization Teneo Strategy LLC.

Not only does Azerbaijan hire US lobbying organizations to further its interests in the US, but also it has tried to violate US laws in order to conceal its lobbying deals and activities with those firms. There have been several reports from lobbyists who chose to speak on condition of anonymity that Azerbaijani government tried to hire some lobbying organizations and work with them without registering and disclosing those deals under the Foreign Agents Registration Act (FARA). According to these reports, the lobbying firms backed away and didn’t pursue a potential contract with the Azerbaijani Embassy. However, Texas Democratic Rep. Henry Cuellar, co-chair of the Congressional Azerbaijan Caucus, together with his wife Imelda Cuellar, allegedly accepted approximately $600,000 in bribes and was charged with taking bribes from an oil and gas company owned by the government of Azerbaijan and trying to use his congressional influence to benefit Azerbaijan’s government.

Overall, Azerbaijani lobbying efforts in the USA seem to be quite productive. The country is spending millions of dollars on high-level engagement and advocacy campaigns and one can notice the results. Despite Armenian lobby groups’ continued efforts, Section 907 of the Freedom Support Act has been continuously waived by US presidents. Azerbaijan has managed to find more supporters in the Congress to promote its interests. Though much of its lobbying activities are disclosed, Azerbaijan’s efforts to bypass American laws and basically bribe US officials should raise concerns about such illegal lobbying practices.

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