Last week, federal prosecutors launched a bombshell indictment against sitting New York City Mayor Eric Adams. Among a range of charges, Adams is accused of covertly funneling foreign funding, primarily out of Turkey, into his election campaigns. He then allegedly pushed pro-Turkish policies while in office—making him, for all intents and purposes, an effective foreign agent on behalf of the Turkish government.
The indictment is shocking for a range of reasons, and joins a burst of other indictments recently filed in the foreign lobbying space. But while most of the recent revelations have centered on illicit lobbying networks in Washington, the Adams indictment points in the opposite direction: to the fact that foreign regimes are no longer targeting just officials in Washington, but local officials around the U.S. as well.
Indeed, the Adams charges follow directly on the heels of another recent indictment that highlights this new—and potentially even more concerning—paradigm in the world of foreign lobbying efforts. As prosecutors alleged last month, an American named Linda Sun secretly acted as an agent for the Chinese government, helping Beijing spread its influence efforts to new U.S. audiences.
The many duties that Sun allegedly performed included blocking Taiwanese representatives from meeting with American officials, forging signatures to issue official proclamations celebrating Chinese representatives, and even blocking at least one U.S. official from mentioning China’s crimes against Uyghurs, which the United States has labeled as genocidal. In return, she and her husband allegedly received millions of dollars, tickets to elite events, and even “Nanjing-style salted ducks” prepared by the personal chef of a Chinese officials.
But Sun’s pro-Beijing work didn’t take place in Washington. Rather, it took place in Albany, New York—and occurred while Sun worked as the top aide to New York Gov. Kathy Hochul. That is, Sun’s Chinese handlers didn’t want her targeting federal officials, but instead targeting the kinds of state-level officials and legislators who’ve long escaped foreign lobbying scrutiny.
Now, with Sun indictment—and for the first time in U.S. history—we’ve gained insight into how and why foreign regimes target state-level governments, and how they attempt to influence state-level officials in the United States. It is a watershed moment—and one that, given the paucity of attention paid to the topic previously, is almost certainly an indicator of a far bigger, far broader problem.
For decades, the topic of foreign influence campaigns had long escaped notice in Washington, with the number of convictions for related crimes limited to single digits in the decades leading up to 2016. That all changed with the rise of former President Donald Trump and the swirl of foreign lobbyists that he ushered into the White House. In the years since, U.S. officials have finally begun enforcing the country’s foreign lobbying regulations, which require lobbyists to register their work and their payments with the Justice Department. There has now been, in many ways, an unprecedented effort at enforcing these regulations.
But that attention has focused almost exclusively on what has taken place at the federal level, in and around Washington. Despite the nation’s federal governing structure, little attention has ever been paid to lobbying efforts aimed at state-level governments, from governors’ offices to state legislatures. Even on the academic side, it would appear that there has never been a comprehensive study of how foreign regimes lobby officials outside the federal government.
A quick survey of recent news stories, however, indicates that the issue deserves far more attention—and far more concern.
The Sun case, for instance, highlights how Beijing has broadened the aperture of its lobbying efforts far beyond Washington—and done so for a relative pittance. Yet the New York charges aren’t the first time that China has been accused of meddling in U.S. state-level governments. In 2022, scholar Flora Yan published a series of investigations into China’s “subnational lobbying campaign[s]” in the United States, tracing the initial efforts to the late 2000s, beginning in California. As Yan wrote, in 2009, Chinese officials launched a lobbying effort aimed at thwarting a proposed California resolution aimed at creating a “Tibet Day” and condemning Beijing’s violent crackdowns against Tibetan protesters.
At the time, Chinese diplomats utilized traditional lobbying tactics, primarily by meeting face-to-face with local legislators. “They were very polished, very determined to express their opinion. At the end of the conversation, they asked me to reconsider moving forward with the bill,” one legislator later said to journalist Tim Johnson. “They talked about desiring good relations, which is perhaps code for, ‘You criticize us at your own risk.’”
Another observer said he’d never seen “foreign consular officials lobbying at our state level in such a blatant and aggressive way. To suggest that such activity is irregular is to state the obvious.” Still, as unprecedented as the effort may have been, the push eventually worked, and the motion to support Tibet was eventually killed. In the process, a new model was created—one that saw foreign governments directly lobbying not legislators in Washington, but in state capitols in Sacramento and far beyond.
Soon, other regimes began following suit. In 2021, a USA Today investigation revealed that Saudi Arabia had broadened its lobbying efforts to target state-level officials around the United States, from Pennsylvania to Alaska, all “part of a new Saudi government lobbying strategy.” Taking place in the aftermath of revelations that Saudi Arabia had assassinated and dismembered journalist Jamal Khashoggi, the lobbying push was part of a far broader portfolio out of Riyadh intended to improve its image. And the push apparently had its intended effect; as one of the interlocutors whom Saudi officials met with said, “There was a huge message of change and progress.”
Elsewhere, foreign governments have increasingly used cutouts to circumvent U.S. lobbying laws and contact state-level officials directly. For instance, the head of the Hungarian state-funded Danube Institute—one of the primary organizations seeking to improve the image of Hungarian Prime Minister Viktor Orban—traveled to Tennessee last year to directly address local legislators. As a result of the visit, the Tennessee legislature passed a formal resolution praising the work of the Danube Institute, describing it as an “extraordinary” organization whose members have “distinguished themselves in the realm of international affairs.” The resolution was the first of its kind, and it passed easily—despite at least one state legislator calling the Danube Institute “an organization tied to an authoritarian.”
Occasionally, multiple nations lobby the same state-level officials in the United States, though often for competing reasons. This pattern was seen most clearly in the cases of Armenia and Azerbaijan, which each spent years lobbying state-level officials regarding the status of the enclave of Nagorno-Karabakh. Armenian lobbyists focused on convincing legislators to formally recognize the independence of the breakaway region, with states such as Hawaii and Michigan recognizing the territory as an independent republic. Azerbaijan, meanwhile, launched lobbying campaigns at officials to recognize the region as a part of Azerbaijan proper, finding success in states such as Arizona and New Mexico.
Given Azerbaijan’s recent incursions into Nagorno-Karabakh, ethnically cleansing the region of remaining Armenians, such debate is now largely moot—though that hasn’t stopped Azerbaijan from feting state-level officials, with legislators from Maine recently traveling to the region and praising their Azerbaijani hosts for taking them to the “liberated territories.”
These are just the handful of examples that we know about; given the lack of attention—and prior to this month, lack of indictments—the issue is almost certainly much larger and much more insidious. But federal officials have at least begun waking up to the problem, and they have started to alert their state-level counterparts.
A 2022 statement from the National Counterintelligence and Security Center (NCSC)—part of the U.S. Office of the Director of National Intelligence—focused directly on these state-level threats, and in particular those led out of Beijing. China “understands U.S. state and local leaders enjoy a degree of independence from Washington and may seek to use them as proxies to advocate for national U.S. policies Beijing desires,” the statement read, pointing directly to policies concerning Tibet, Xinjiang, and Taiwan. As the statement continued, “[l]eaders at the U.S. state, local, tribal, and territorial levels risk being manipulated to support hidden [Chinese] agendas.”
The statement coincided with a joint advisory from the NCSC, FBI, and Department of Homeland Security to U.S. state-level officials regarding Chinese influence operations, with NCSC chief Michael Orlando noting to the Wall Street Journal that Beijing had “become more aggressive and pervasive” in recent years.
But these operations are not simply about effecting immediate policy changes. As FBI Director Christopher Wray said in 2022, “The Chinese government understands that politicians in smaller roles today may rise to become more influential over time. So they look to cultivate talent early—often state and local officials—to ensure that politicians at all levels of government will be ready to take a call and advocate on behalf of Beijing’s agenda.”
Such an understanding, and such efforts, are hardly limited to Beijing. Governments around the world, especially authoritarians in places such as Azerbaijan or Hungary, have realized just how open state-level officials are, and just how susceptible they are to foreign lobbying efforts. In a certain sense, this mirrors the positions taken regarding federal officials until very recently; it’s only in the past few years that investigators and regulations have bothered enforcing foreign lobbying laws at the federal level.
The time is long overdue for similar efforts at the state level, even among smaller U.S. states—all of which will, for the first time, finally reveal just how broad, and just how deep, these foreign lobbying efforts now run.
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