Shortly after President Donald Trump was inaugurated last year, top Republican fundraiser Elliott Broidy offered Russian gas giant Novatek a $26 million lobbying plan aimed at removing the company from a U.S. sanctions list, according to documents obtained by The Intercept.

Broidy is a Trump associate who was deputy finance chair of the Republican National Committee until he resigned last week amid reports that he had agreed to pay $1.6 million to a former Playboy model with whom he had an affair. But in February 2017, when he laid out his lobbying proposal for Novatek, he was acting as a well-connected businessman and longtime Republican donor in a bid to help the Russian company avoid sanctions imposed by the Obama administration. The 2014 sanctions were aimed at punishing Russia for annexing Crimea and supporting pro-Russia separatists in eastern Ukraine.

In February 2017, Broidy sent a draft of the plan by email to attorney Andrei Baev, then a Moscow- and London-based lawyer who represented major Russian energy companies for the firm Chadbourne & Parke LLP. Baev had already been communicating with Novatek about finding a way to lift U.S. sanctions.

Broidy proposed arranging meetings with key White House and congressional leaders and generating op-eds and other articles favorable to the Russian company, along with a full suite of lobbying activities to be undertaken by consultants brought on board. Yet even as he offered those services, Broidy was adamant that his company, Fieldcrest Advisors LLC, would not perform lobbying services but would hire others to do it. He suggested that parties to the deal sign a sweeping non-disclosure agreement that would shield their work from public scrutiny.

The plan is outlined in a series of emails and other documents obtained by The Intercept. Broidy and Baev did not dispute the authenticity of the exchanges but said the deal was never consummated.

In March, Bloomberg News reported that Broidy “offered last year to help a Moscow-based lawyer” — Baev — “get Russian companies removed from a U.S. sanctions list.” The news outlet did not identify the Russian firms or provide details of that proposal.

“At the time when I was a partner of Chadbourne & Parke LLP I had very preliminary discussions with Elliott Broidy with regard to possible engagement of him as a strategic consultant with regard to a possible instruction by one of my corporate clients. This instruction has never materialized,” Baev told The Intercept in an email. “Nor did I or Chadbourne provide any services to any other individual or entity in connection with any attempt to remove any Russian company or an individual from the US sanctions list.”

Broidy told The Intercept through a spokesperson that Baev had approached him about the proposal, but that Broidy had decided not to go through with it for political reasons. “At the time Mr. Baev had approached us he was then a managing partner of a major U.S. law firm and the new Administration had indicated an interest in normalizing relations with Russia and potentially easing sanctions,” Broidy told The Intercept in a statement provided by his spokesperson. “Subsequently, the geopolitical landscape changed and I made the decision not to pursue it.”

Baev was introduced to Broidy in October 2016, before Trump was elected. At the time, Broidy was serving as a top fundraiser for the Trump campaign; he would later become vice chair of Trump’s inaugural committee before transitioning to his most recent position at the RNC.

Broidy began sharing drafts of his lobbying plan with Baev by December. That month, he also sent Baev a Wall Street Journal article headlined “France Poised for Pro-Russia Pivot.”

The article describes how François Fillon and Marine Le Pen, the center-right and far-right candidates, respectively, during the 2017 French presidential election, both opposed punitive sanctions levied by French President François Hollande against Russia for its activity in eastern Ukraine. “With U.S. President-elect Donald Trump also promising friendlier relations with Moscow, Western agreement on sanctions against Russia could crumble,” the article says. Fillon and Le Pen were eventually defeated by France’s current president, Emmanuel Macron.

As the discussions continued, Sen. John McCain, R-Ariz., and others began pushing legislation that would take the decision on whether to lift sanctions out of Trump’s hands and put Congress in control, a development that Novatek apparently recognized as a threat given that Broidy’s power to affect policy lay in his presumed influence with Trump.

In January 2017, Baev wrote to Broidy asking whether McCain’s bill would put their efforts at risk. “The client is asking how our road map would be affected by a new bill sponsored by Senator McCain to codify the existing sanctions and to impose new ones as a matter of federal law which the Administration will not be in a position to lift without consent of the US Congress. What are your thoughts on this?”

Broidy responded: “We need to convince McCain to abandon or water down the bill while we push the admin and other members of Senate to water down and vote no. Not a game changer.”

In a proposal dated February 23, 2017, Broidy told Baev that he had found “many influential experts, lobbyists, and attorneys” who were “willing and able to work immediately on your behalf and on behalf of Novatek.” The document, marked “strictly-confidential, attorney client privilege,” lays out a plan for a two-year influence campaign that Broidy claimed could dilute McCain’s bill and lift sanctions by February 2019.

The plan outlines a 25-step “Roadmap” that includes getting buy-in from congressional Foreign Relations committees, as well as outreach to the White House, the Treasury, and the Commerce, State, and Justice departments.

It also lists “issues for Congress” that would have to be overcome in order to implement the plan, including progress on agreements to resolve the situation in Ukraine. Congress would also “need information as to whether Russia did indeed hack DNC and attempt to influence US Presidential election,” according to the document.

Broidy added: “Congress would require agreement with Russia that Russia will not do so again.”

Broidy proposed a one-time fee of $500,000 to Fieldcrest, followed by monthly payments starting at $300,000 and eventually rising to $500,000. He proposed an additional monthly $300,000 for “attorneys, lobbyists, experts and other consultants that Fieldcrest Advisors will recommend.” The documents include a chart estimating the expenses for the next three years:

Baev told The Intercept that the conversations were preliminary in nature and that he and Broidy spoke of their own volition. “Neither I nor Chadbourne & Parke LLP has ever been instructed by any Russian company or individual to represent them in connection with this matter,” he said in an email. “For ethical reasons, I cannot address whether I was asked to perform any such services, but whether I or the firm was contacted or not, we were never engaged to perform these services and never performed them.”

The documents show, however, that Novatek asked Baev to discuss retaining Broidy to help the company get off the sanctions list, and Novatek appears to have specifically referenced Broidy’s proposal in doing so. In February, Baev had received a letter from Denis Solovev, the director of communications for Novatek, marked “confidential.”

“I am authorized by the management of Novatek to contact you and express our interest in your services related to removing Novatek from the US sanctions list,” wrote Solovev. “We would like to discuss with you your proposed road map.”

Throughout the documents and correspondence, Broidy articulates a desire to avoid publicly registering under the Lobbying Disclosure Act or the Foreign Agent Registration Act — laws that require influence peddlers to be transparent about who is funding their lobbying campaigns, and, in the case of FARA, whom they are speaking to. In an effort to avoid such disclosures, Broidy proposed that he and his consulting company, Fieldcrest, would “advise on the creation of an appropriate team” and “provide advice and manage coordination of the team.” “Fieldcrest is not a ‘lobbyist’ or registered ‘foreign agent’ and … at no time would be acting in such capacities,” Broidy noted in his outline, which also suggests that each team member be required to sign a confidentiality and non-disparagement form.

One hiccup came when Broidy sought legal advice about the plan. Elliot Berke, an attorney and managing partner at Berke Farah LLP, reviewed Broidy’s proposal and flagged the avoidance of lobbying registration as a problem. “Fieldcrest offers a somewhat detailed ‘Roadmap,’ which in and of itself could be viewed as providing strategic advice to influence US policy,” Berke wrote to Broidy in February, suggesting that he may have already run afoul of FARA. “The fee amounts and scope also would not support a claim that Fieldcrest’s activities would be limited to non-FARA-registrable administrative activities.” Berke also noted that “some of the characterizations” in the plan “could be construed to suggest that Fieldcrest has already engaged in registrable activity.”

Berke closed the letter: “Not the conclusion you were hoping for, I know, but happy to discuss more next week.”

Broidy consulted Berke Farah to ensure that his plan was legal, and the answer he received was a factor in the decision not to move forward with the agreement, according to his statement to The Intercept. “As with any matter, I took early steps to ensure that any proposed engagement, if one had gone forward, was in compliance with all applicable laws, which is why I consulted with my attorneys. As I’ve consistently stated though, I did not wish to be a lobbyist or FARA agent and would have declined any engagement requiring such steps.”

Berke did not respond to a request for comment from The Intercept.

Broidy has worked to funnel money into the U.S. political system for others, however. Last month, the Associated Press reported that Broidy received millions of dollars from George Nadar, a witness in Special Counsel Robert Mueller’s investigation and a close confidant of Abu Dhabi Crown Prince Mohammed bin Zayed. AP reported that Broidy received that money weeks before he made personal donations to congressional campaigns in an effort to shape a bill critical of Qatar, which the United Arab Emirates is currently blockading. The New York Times also reported that Broidy was reimbursed by Nadar after he funded an October conference that was highly critical of Qatar, which was confirmed by documents obtained by The Intercept. The UAE has contracts with a private security company Broidy owns that are worth “hundreds of millions of dollars,” according to the Times.

Broidy has blamed Qatar for the hack and disclosure of his emails. His attorney wrote a public letter to the Qatari ambassador to the U.S. blaming the Gulf nation for spreading “false and stolen information about him,” and claiming that Broidy had “irrefutable forensic evidence tying Qatar to this unlawful attack.” Broidy has since filed a lawsuit seeking damages from the Qatari government.

The Qatari Embassy did not respond to The Intercept’s requests for comment. The documents were provided to The Intercept anonymously.

Top photo: Russian President Vladimir Putin, center, accompanied by Novatek founder Leonid Mikhelson, second left, and Russia’s energy minister Alexander Novak, left, visits a liquefied natural gas plant in the port of Sabetta on the Yamal peninsula beyond the Arctic Circle on Dec. 8, 2017.