Americans for Transparency logo
Home/Investigations/Continental Strategy
FARA #7545ActiveCorporate — Lobbying & Strategic Consulting

Continental Strategy LLC

Continental Strategy LLC is a multi-principal FARA registrant whose filed documents span more than a dozen foreign principals, most of them governments. Key findings:

Parent Company
Continental Strategy LLC
Ultimate Owner
Carlos Trujillo (President/Founder; sole owner of the single-member LLC per the 2025-02-24 registration statement)
United States
Headquarters
Washington, DC

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 principals simultaneously, making it one of the more prolific multi-principal FARA registrants in Washington. Its foreign principals as disclosed in eFARA filings include the Government of the Republic of Kazakhstan, the Royal Thai Government (Ministry of Commerce), the Republic of Peru (connection ended 01/31/2026), the Republic of Kenya, the Dominican Republic's Ministerio de Industria, Comercio y Mipymes on behalf of the Asociacion Dominicana de Zonas Francas, Inc., and the Ministry of Foreign Affairs of the Co-operative Republic of Guyana. Not all are governments: Reformatics FCZ is a corporation and the Democratic Party of Albania is a political party.

Continental Strategy's filing record, FARA documents on file and the largest unrepresented collection identified in this investigation's gap audit, spans registration statements, multiple Exhibit ABs (one per foreign principal), supplemental statements, and a large number of short forms for individual short-form registrants including Carlos Trujillo, John Barsa, Alberto Martinez, Alejandro Garcia, Eric Farnsworth, and Doug MacGillivray.

The firm's short-form registrants include former senior government officials, making it a revolving-door operation connecting the Trump-era foreign policy establishment to foreign principals seeking U.S. advocacy.

Investigation Summary

Continental Strategy LLC is a multi-principal FARA registrant whose filed documents span more than a dozen foreign principals, most of them governments. Key findings:

• FARA documents on file; the largest unlinked collection in this investigation's audit

• Foreign principals named in Exhibit ABs stamped 2025-02-24 to 2026-08-10: Guyana, Haiti, Dominican Republic (two principals), Reformatics FCZ (Georgia), Democratic Party of Albania, Bosnia and Herzegovina, Japan, Peru, Kenya, Thailand, Bahrain, Kazakhstan, Republic of Srpska, Kurdistan Regional Government (Iraq)

• 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

Q1

Are there conflicts of interest between simultaneous representation of competing foreign governments?

Q2

What specific policy outcomes have been achieved for each foreign principal?

Q3

How does Carlos Trujillo's OAS ambassadorship inform his current lobbying clients?

Q4

Are disbursement amounts properly reported in supplemental statements?

Red Flags

⚠

Simultaneous representation of multiple 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

⚠

FARA documents filed — scale suggests extensive ongoing foreign government influence work

Know someone who needs to see this?

Share on X

SOURCE 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 Transparency (AFTorg). See our Legal Framework and Editorial Standards.

From the DOJ record

Continental Strategy LLC: what the FARA filings show

Is Continental Strategy LLC a registered foreign agent?
Continental Strategy LLC is registered with the U.S. Department of Justice under the Foreign Agents Registration Act (FARA) as registrant No. 7545 since Feb 24, 2025. DOJ lists the registration as active.
Who does Continental Strategy LLC work for?
Its filings name 15 foreign principals: Democratic Party of Albania (Albania), Ministry of Foreign Affairs - Co-operative Republic of Guyana (Guyana), The Embassy of Peru on behalf of The Republic of Peru (Peru), Kurdistan Regional Government (Iraq), Republic of Srpska (Bosnia & Herzegovina), Government of the Republic of Kazakhstan (Kazakhstan), Embassy of the Kingdom of Bahrain (Bahrain), Republic of Kenya (Kenya), office of Commercial Affairs, Royal Thai Embassy on behalf of the Ministry of Commerce. Royal Thai Government (Thailand), Ministerio de Industria, Comercio y Mipymes de la Republica Dominicana on behalf of Asociacion Dominicana de Zonas Francas, Inc. (Dominican Republic), Embassy of Japan (Japan), Bosnia American Alliance on Behalf of the Ministry of Foreign Affairs of Bosnia and Herzegovina (Bosnia & Herzegovina), Reformatics FCZ (Georgia), Republic of Haiti (Haiti) and El Departamento Nacional de Investigaciones de la Republica Dominicana (Dominican Republic). Under FARA, a foreign principal is the foreign government, party, company or person on whose behalf a registrant acts.
Who works on Continental Strategy LLC's FARA registration?
8 people have filed a short-form registration statement under this registration, the form FARA requires of each person who acts for the foreign principal: Barsa, John, De La Torre, Enrique, Farnsworth, Eric, Garcia, Alejandro, Hassanein, Wesam, MacGillivray, Doug, Martinez, Alberto and Trujillo, Carlos.
What has Continental Strategy LLC filed with the Justice Department?
DOJ's public file holds 110 current filings for the registration, the most recent an Informational Materials stamped Sep 30, 2026. By type: 42 Short-Form, 25 Amendment, 22 Informational Materials, 15 Exhibit AB, 4 Supplemental Statement and 1 Exhibit C. The filings are public at efile.fara.gov.

Most recent filings

Source: U.S. Department of Justice, FARA eFile, registration No. 7545. Read from AFTorg's copy of the DOJ record, refreshed several times a day. A FARA registration is a public disclosure; it is not a finding of wrongdoing.