U.S. PR Firm Aiding Libya May Have Violated Federal Law

Evidence is mounting that the Monitor Group, which has been caught promoting Libya in the United States under a $3 million contract, may have violated numerous federal laws.


July 2006 memo from CEO Mark B. Fuller to Libyan Abd Allah al-Sanusi unveiled an ambitious pro-Gaddafi PR campaign for both the United States and Britain. Al-Sanusi is a reputed Libyan intelligence chief. Fuller wrote:

We will created a tailored program to introduce and bring to Libya a meticulously selected group of independent and objective experts. … We will jointly identify relevant policy-makers and influencers, politicians, (both Democratic and Republican), government officials, thought leaders and academics and journalists.

Earlier this month, a 2007 contract between the Libyan government and the Monitor Group was uncovered by Libyan rebels. Its release has caused an international furor and caused the head of the London School of Economics, which collaborated with Monitor, to be dismissed. The Monitor contract states the company waged a PR campaign in Britain and in the United States to “enhance the profile of Libya and Muammar Gaddafi.”

Federal law specifically states that “public relations counsel” on behalf of a foreign government must register with the Justice Department. Section 611  of the United States Code defines such a counselor as:

Any person who engages directly or indirectly in informing, advising, or in any way representing a principal in any public relations matter pertaining to political or public interests, policies, or relations of such (foreign) principal.

The company may also run afoul of federal lobbying registration requirements under the Legislative Disclosure Act of 1995. Anyone engaged in any “lobbying activities” on behalf of domestic or foreign interests must register with the U.S. Congress through the Clerk of the House of Representatives.


Directors and officers of the firm are liable for federal penalties and imprisonment for willful omission of foreign agent activity.

In 2007 the Monitor Group apparently — and secretly — paid untold sums of money to former Clinton national security official Joseph Nye and to anti-capitalist American academic Benjamin Barber. Both were recruited by Monitor to write and speak favorably about Libya. They appeared on television talk shows and published opinion articles in print media such as the New Republic and the Washington Post.

Jonathan Wiener, blogging on cbsnews.com, links other Americans to the Monitor payroll, including Harvard University’s Robert Putnam and Francis Fukuyama of Johns Hopkins. It is not yet known how many other American “experts” were on the Monitor payroll for Libya.

A review by PJM of the Justice Department’s Foreign Agents Registration Act (FARA) database does not identify any Monitor registration or filing on behalf of any government. A Justice Department source has confirmed to PJM that the Monitor Group has neither registered nor filed on behalf of any Libyan principal or government entity. There also is no Monitor lobbying reporting or registration with the Clerk of the House.

The Sunlight Foundation believes the Monitor Group is in violation of  FARA — Paul Blumenthal of Sunlight says the July 2006 Monitor memo confirms it. He cites the part of the memo that says Monitor will begin identifying “critical figures … among policy makers, government, media, think tanks, academics, journalists, private sector companies and lobby groups,” providing support for “publication of positive articles on Libya,” and coordinating with Libya’s “existing lobbyists to ensure an integrated program.”


Some claim the Monitor’s contract was with Gaddafi’s second son — Saif al Islam al-Gaddafi — and not with Col. Muammar Gaddafi and his government. Saif founded a “charity” called the Gaddafi International Charity and Development Foundation. He moved in British high society and met with many high-ranking British officials. Saif gave a $2.5 million gift to the London School of Economics, and was awarded a Ph.D from the university. Joseph Nye is thanked by Saif in his dissertation for helping him with it.

Benjamin Barber told Wiener:

I didn’t take money from Gaddafi. The money to Monitor was coming from the Gaddafi Foundation, funded by Saif, who was providing the impetus for reform.

Yet this appears to be irrelevant — the federal reporting law applies to governments, individuals, and organizations — and also false: the 2006 and 2007 contracts make no reference to Saif or his charity. The 2007 document says it is the between the Libyan government and the “Monitor Group Foreign Government Services LLC.”

Monitor operates 26 worldwide offices. There is a possibility the Libyan principals paid Monitor to one of its overseas offices, perhaps in London. If the money was not repatriated to the United States, it is possible that the firm might not have to report the funds to the U.S. government.

This theory appears weak, however: the contract’s payment terms are in U.S. dollars, not British pounds or euros. In addition, a financial analysis of the Monitor Group by Vault Worldwide says the company co-mingles its worldwide receipts into the headquarters — which is in Cambridge, Massachusetts. As noted in Wikipedia:


Managed as an integrated system of international offices, Monitor’s offices are not treated as separate profit-generating units, but rather as different posts of a single company. The profits generated by all offices are brought in together as a firm.

The firm was founded in 1983 by six faculty members of the Harvard Business School, and most of today’s senior officers are from HBS. They built an unusual global PR firm that talks in future-speak. There are no presidents or corporate spokespersons — just “thought leaders” and “chief knowledge officers.”

The Monitor Group certainly is a massive global firm. It has 1,500 employees, although in 2008 a poor economy forced it to lay off about 20% of its workforce. A Securities and Exchange Commission listing actually identifies the Monitor Group as 24 different companies — all located at the same Cambridge address. The SEC listing and other documents suggest the multinational firm also operates its own hedge fund and mutual fund. Their equity company, Monitor Ventures, is a private equity company with $2 billion under management.

Les Campbell, a Middle East expert with the National Democratic Institute, recalls his organization being pestered for many years by Monitor over Libya:

Libya was up to this sort of thing for a long time through the Monitor Group. … I don’t know how many DVDs I got of Gaddafi talking about democracy.

Campbell recalls two Monitor meetings in his office in Washington, D.C. One was with Gaddafi’s son, Saif. The other was with Benjamin Barber and the executive director of Saif’s charity, Dr. Youssef Mohamed Sawani:


The Monitor Group once brought a guy in named Sawani, who was the head of the Gaddafi foundation. He came with Benjamin Barber actually to come and see us. We met with him and Barber. I felt it was very unsatisfactory.

The 2006 contract called for American and British delegations to go to Libya. Campbell told PJM:

[I knew Monitor] organized a whole series of trips to Libya for various luminaries. So Frank Fukiyama, for example went to Libya, a kind of a public intellectual. Benjamin Barber went too, kind of a public intellectual.

The Sunlight Foundation has reported that Monitor executives are looking into FARA requirements to determine if they are afoul of the law.


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