Continental Strategy LLC
Continental Strategy LLC is a multi-principal FARA registrant with 75 filed documents across 6+ foreign government clients. Key findings:
Corporate History
Continental Strategy LLC is a Washington, DC-based lobbying and strategic consulting firm founded by Carlos Trujillo, a former U.S. Ambassador to the Organization of American States (OAS) under the Trump administration. The firm specializes in international trade, diplomatic relations, and government affairs across Latin America, Asia, and Africa.
Continental Strategy has registered under FARA for multiple foreign government clients simultaneously, making it one of the more prolific multi-principal FARA registrants in Washington. Its client roster as disclosed in eFARA filings includes the Government of the Republic of Kazakhstan, the Royal Thai Government (Ministry of Commerce), the Republic of Peru, the Republic of Kenya, the Dominican Republic free trade zone authority, and the Ministry of Foreign Affairs of Guyana.
With 75 total FARA documents on file — the largest unrepresented collection identified in this investigation's gap audit — Continental Strategy's filing record spans registration statements, multiple Exhibit ABs (one per foreign principal), supplemental statements, and a large number of Short Forms for individual registered agents including Carlos Trujillo, John Barsa, Alberto Martinez, Alejandro Garcia, Eric Farnsworth, and Doug MacGillivray.
The firm's network of registered agents includes former senior government officials, making it a revolving-door operation connecting the Trump-era foreign policy establishment to foreign government clients seeking U.S. advocacy.
Investigation Summary
Continental Strategy LLC is a multi-principal FARA registrant with 75 filed documents across 6+ foreign government clients. Key findings:
• 75 total eFARA documents — largest unlinked collection in this investigation's audit
• Foreign principals: Kazakhstan, Thailand, Peru, Kenya, Dominican Republic, Guyana
• Key agents: Carlos Trujillo (fmr. U.S. Ambassador to OAS), John Barsa (fmr. USAID Acting Administrator), Eric Farnsworth, Alberto Martinez, Doug MacGillivray
• Multiple simultaneous foreign government contracts — potential conflicts of interest
• All agents filed FARA Short Forms as required
Unanswered Questions
Are there conflicts of interest between simultaneous representation of competing foreign governments?
What specific policy outcomes have been achieved for each foreign principal?
How does Carlos Trujillo's OAS ambassadorship inform his current lobbying clients?
Are disbursement amounts properly reported in supplemental statements?
Red Flags
Simultaneous representation of 6+ foreign governments raises conflict-of-interest questions
Former senior U.S. officials leveraging government relationships for foreign principals
Kazakhstan client amid concerns about authoritarian governance
75 documents filed — scale suggests extensive ongoing foreign government influence work
Related Entities
Key Personnel (6)
Carlos Trujillo
Managing Partner / Registered Agent
Former U.S. Ambassador to the OAS (Trump administration). Primary registered agent and firm founder.
John Barsa
Registered Agent
Former Acting Administrator of USAID. Filed multiple Short Forms across different client relationships.
Alberto Martinez
Registered Agent
Filed Short Forms for multiple Continental Strategy foreign principals.
Alejandro Garcia
Registered Agent
Filed Short Forms for Continental Strategy foreign principal work.
Eric Farnsworth
Registered Agent
Filed Short Forms in December 2025.
Doug MacGillivray
Registered Agent
Filed Short Form in January 2026.
Documented Money Flows (4)
U.S. lobbying and strategic communications
U.S. trade advocacy
U.S. diplomatic and trade advocacy
U.S. diplomatic and trade advocacy
FARA Documents (75)
Event Timeline
FARA Compliance Notes
Continental Strategy is FARA-registered and files required documents
Multiple simultaneous foreign principal relationships require separate Exhibit ABs per client
Short Form filings are current for all registered agents
Supplemental statements filed on schedule
Legal Disclaimer
This profile is based on publicly available FARA filings. Continental Strategy LLC is a legally registered foreign agent under FARA. Carlos Trujillo and all named agents have not been found guilty of any wrongdoing. The analysis represents AFNPT's interpretation of public records for educational purposes.
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Share on XSOURCE ATTRIBUTION: All information on this page is derived from publicly available records including FARA registrations filed with the U.S. Department of Justice, IRS Form 990 filings, state corporate records, SEC filings, and attributed news reporting. This analysis is provided for educational purposes by Americans For Non-Profit Transparency (AFNPT). See our Legal Framework and Editorial Standards.