Paul Manafort, the former chairman of Donald Trump’s presidential campaign, might register as a foreign agent with the Department of Justice, a spokesman for Manafort said Wednesday.

The spokesman said the onetime lobbyist and consultant is “taking appropriate steps in response to the guidance” he was given by the Justice Department.

“Since before the 2016 election, Mr. Manafort has been in discussions with federal authorities about the advisability of registering under FARA [the Foreign Agents Registration Act] for some of his past political work,” spokesman Jason Maloni said in a statement.

“Mr. Manafort received formal guidance recently from the authorities and he is taking appropriate steps in response to the guidance. The work in question was widely known, concluded before Mr. Manafort began working with the Trump Campaign and was not conducted on behalf of the Russian government.”

Pressed on what the Justice Department advised and whether Manafort would be registering as a foreign agent, Maloni declined to comment further.

“For now you’ll have to use what I provided,” he wrote in an email to The Hill.

Lobbying firms tied to Manafort and his prior work for the political party of ousted Ukrainian president Viktor Yanukovych are in the process of retroactively registering with the Justice Department. 

Two firms, Podesta Group and Mercury, represented the European Centre for a Modern Ukraine, a Brussels-based nonprofit organization that worked to create a closer relationship between the United States and Ukraine. The work lasted from 2012 to 2014.

The firms are now registering with the Justice Department for work they did that could have benefitted Ukraine and a pro-Russia political party, the firms said in separate statements. 

The Centre has ties to Yanukovych and the Party of Regions, his pro-Russia political party.

The Associated Press last year reported that Manafort’s firm — DMP International, which was advising Yanukovych at the time — introduced Mercury and Podesta Group to the Centre and helped direct some of the lobbying strategy. 

Days after that report, Manafort left Trump’s campaign.

Now, Manafort is among the central figures in federal investigations of Russian election meddling and potential ties between Trump’s associates and the Kremlin.

Manafort has offered to appear before both the House and Senate Intelligence committees. A spokesman for the former Trump campaign chairman said last month that the testimony would give him the opportunity to “discuss the facts.”

If Manafort does register as a foreign agent, he would be the second member of Trump’s campaign to do so. Former National Security Adviser Michael Flynn formally registered as a foreign agent last month after it was revealed that he had done work that may have benefitted the Turkish government.

Flynn resigned from his top White House post in February amid revelations that he discussed sanctions with Russia’s ambassador before Trump took office and misled Vice President Pence and other administration officials about the nature of those conversations.

Both Mercury and Podesta Group had previously disclosed their work for the European Centre for a Modern Ukraine through the Lobbying Disclosure Act (LDA), which detail a total of $2.2 million in payments from 2012 to 2014 but those forms offer fewer details about the work than foreign lobbying disclosures do.  

Lobbyists for foreign clients can register under the LDA as long as those clients aren’t foreign governments, politicians or entities tied to them.

The client, both Mercury and Podesta Group have said, signed documents stating that it was not “directly or indirectly supervised, directed, controlled, financed or subsidized in whole or in part by a government of a foreign country or a foreign political party.”

The Justice Department’s FARA unit — which polices foreign lobbying disclosures — advised the two firms they should have notified the government about the work. 

“We believe the LDA registration was appropriate for our particular work on the Centre’s behalf. However, we also understand after constructive consultation with FARA Unit staff that their position, which is based on all the information available to them, is that the overall representation is now better classified as a FARA registration,” said Kimberley Fritts, the chief executive of the Podesta Group. 

“We have, and will continue to have, no hesitation doing so to underscore our commitment to transparency,” she said. 

The 28-page filing from the Podesta Group to the Justice Department includes a list of contacts the firm made on clients’ behalf, including to reporters and government officials. 

Also in the filing, a lawyer for the Podesta Group wrote in a letter to the Justice Department that the standard for determining whether a foreign government or party is a “primary beneficiary” of any kind of work is unclear.  

“The Podesta Group acknowledges that, in light of this undefined legal standard, its work on the Centre’s behalf could be interpreted as principally benefiting a foreign government, since the Centre’s purpose was to foster closer ties between Ukraine and the West,” wrote Matthew Sanderson of Caplin & Drysdale. 

The firm’s work included strengthening ties between western countries and Ukraine, with the hopes of having Ukraine included into the European Union. 

Podesta Group set up meetings with Ukrainian and European politicians and business leaders visiting the United States — including former Italian prime minister Romano Prodi; Aleksander Kwasniewski, the former president of Poland who served as the special envoy to Ukraine for European Parliament; former Ukrainian president and former opposition leader Viktor Yushchenko, and other Ukrainian officials. 

In addition to reaching out to journalists about these issues, the firm also contacted officials on Capitol Hill, the State Department, the White House’s National Security Council and other agencies. 

Podesta Group also worked within Europe to have American policymakers promote greater unity with Ukraine.  

Updated at 4:05 p.m.