“Monitor is not a lobbying group.”

That was the assertion in one of a series of memos between The Monitor Group and the Government of Libya that were leaked by the Libyan opposition to Muammar Gaddafi’s now-tenuous rule of Libya. The memos, leaked in 2009, detail an extensive plan to promote the Libyan view to government officials and the American public that may leave many wondering why the firm never registered as a foreign lobbying group under the Foreign Agents Registration Act (FARA).

Beginning in 2006, Monitor began work as a consultant for Libya to “Enhance the Profile of Libya and Muammar Qadhafi” and to help the country establish an economic strategy. Monitor stated that it charged the Government of Libya $250,000 a month along with an open expense account that would not total more than $2.5 million.

In a memo dated July 3, 2006, The Monitor Group spelled out their plan of action for the Gaddafi government. This included mapping “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.”

The central focus of the program was the invitation of prominent individuals to visit Libya and talk to regime leaders including Gaddafi and his sons. The July 3 memo lists two qualifications for the selection of visitors, “the appeal of their ideas” and “the strength of their influence in guiding US foreign policy.”

According to The Lobbying Manual published by the American Bar Association, there are a few key definitions that an organization has to meet to be required to register as a foreign agent under FARA. In most cases, whether a firm’s action fall under the definition of the term “political activities” determines their registration status.

The precise definition of “political activities” under FARA is

“…any activity that the person engaging in believes will, or that the person intends to, in any way influence any agency or official of the Government of the United States or any section of the public within the United States with reference to formulating, adopting, or changing the domestic or foreign policies of the United States or with reference to the political or public interests, policies, or relations of a government of a foreign country or a foreign political party.”

The Monitor Group memos outline a strategy that is based on the need to influence both government officials in relation to U.S. policy and public opinion in regards to the Government of Libya and its leaders.

In a 2007 memo The Monitor Group states that their strategy is to “introduc[e] to Libya important international figures that will influence other nations’ policies towards the country.” This memo also states, “Many of the visitors brought to Libya have individually briefed all levels of the United States government including specifically the President, Vice President, Heads of National Security and Intelligence as well as the Secretary of State.”

One visitor to Libya was Nicholas Negroponte, the director of the MIT Media Lab and the founder of One Laptop Per Child. Negroponte’s brother is John Negroponte, at the time the Deputy Secretary of State. The memo indicates that Nicholas Negroponte “briefed his brother and other senior officials in the White House upon his return from Libya.”

Many other visitors are touted for their connections to policy makers in the United States. Author Bernard Lewis is said to have briefed then-Ambassador to Israel Richard Jones and “the entire political and economic staff at the U.S. Embassy in Israel on his visit to Libya.” Professor Benjamin Barber is stated to consult “regularly with … Bill Clinton, Howard Dean, former Senator Bill Bradley.” Anne-Marie Slaughter is listed as an advisor to Barack Obama and a “potential cabinet member.”

Monitor does not only explain their strategy to influence U.S. policy through the visitors program. They also explicitly state their own work in lobbying the U.S. government: “At a critical time when the United States was debating its recognition of Libya, Monitor met with senior officials in the United States government to share its perspective on Libya.” While Monitor may claim it was only sharing “its perspective” it was under contract with the Government of Libya to promote the country and improve its image at the time.

The memos also show Monitor’s work to influence opinion through the publication of articles by participants in the visitors program. Registration under FARA is not limited to the direct publication or dissemination of materials to influence public policy or public opinion. Indirect publication or dissemination is also included under registration requirements.

Monitor cites articles that Princeton professor Andrew Moravcsik wrote after his visit to Libya in Newsweek and the Financial Times and an appearance by Barber on NPR as positive examples of the kind of press that their work for Libya has produced.

Monitor also promotes itself as a voice to the media for discussions about Libya, “Monitor continues to speak directly to the media about Libya, and is willing to be quoted in the international press.”

On February 24 Monitor released a statement explaining “we do not discuss specifics of our work with any client … we are deeply distressed and saddened to witness the current tragic events in Libya. … Our work was focused on helping the Libyan people work towards an improved economy and more open governmental institutions. This is within a context of a period that was widely perceived as holding meaningful potential for reform within, and new opportunity for, Libya. We sought, consistently, to enable such progressive developments.”

(More Sunlight coverage of lobbying by governments facing protests and revolts in the Middle East.)