Significant, or a nothingburger? Paul Manafort and Richard Gates completed their submissions to the Department of Justice to retroactively register under the Foreign Agents Registration Act (FARA), a move prompted in part from revelations about his work in Ukraine on behalf of a pro-Russian political party. The Washington Post’s report on the belated registration suggests that the filing and disclosure of payments may satisfy the DoJ, at least on questions of his status:

A consulting firm led by Paul Manafort, who chaired Donald Trump’s presidential campaign for several months last year, retroactively filed forms Tuesday showing that his firm received $17.1 million over two years from a political party that dominated Ukraine before its leader fled to Russia in 2014.

Manafort disclosed the total payments his firm received between 2012 and 2014 in a Foreign Agents Registration Act filing late Tuesday that was submitted to the U.S. Justice Department. The report makes Manafort the second former senior Trump adviser to acknowledge the need to disclose work for foreign interests. …

Manafort and a former associate in his consulting business, Richard Gates, who also worked for the Trump campaign, disclosed their lobbying campaign on behalf of Ukraine’s Party of Regions in an 87-page document which described the gross receipts the firm received and some details of efforts undertaken to influence U.S. policy toward Ukraine. The filing shows the firm spent nearly $4 million to advance the party’s interests through polling and local salaries in Ukraine, activity that does not ordinarily require U.S. disclosure. The filing does not show how much Manafort made personally in Ukraine or how much his firm netted after expenses.

As part of the filing, Manafort disclosed he met in 2013 with Rep. Dana Rohrabacher, an outspoken California Republican known for advocating closer ties between the U.S. and the Kremlin.

CNN reported that the filing may not change Manafort’s status or any investigation into his activities, especially the special counsel probe into Russian interference in the election:

The registration doesn’t end the years-long US probe of Manafort and his firm which, because of Manafort’s role as Trump campaign chairman last year, have become part of the broader investigation now led by special counsel Robert Mueller looking into Russian meddling in the 2016 election.

US investigators continue to scrutinize Manafort’s tax and business records to determine whether any criminal violations occurred, according to the officials briefed on the investigation.

Well … maybe. According to Manafort spokesman Jason Maloni, Manafort has been working on this filing for almost a year, since shortly after his exit from the Trump presidential campaign:

“Today, Paul Manafort registered with the Department of Justice’s FARA unit for his work on behalf of Ukraine’s Party of Regions. He started this process in concert with the FARA unit in September, before the outcome of the election and well before any formal investigation of election interference began. Paul’s primary focus was always directed at domestic Ukrainian political campaign work, and that is reflected in today’s filing. Paul has appreciated the professionalism and guidance of the FARA unit throughout this process.”

If the only contact made by Manafort during this period was with Rohrbacher, there may not be all that much to investigate. The filing now will cover that in terms of disclosure, and as the Post’s Tom Hamburger and Rosalind Helderman report, the DoJ rarely prosecutes for FARA violations that don’t have any other crime involved. FARA disclosure requirements are broader than those for domestic lobbyists, including contacts with think tanks and activist groups, but Manafort insists that his work with the Party of Regions was more EU-focused than US-focused. If that’s the case, then there won’t be much to investigate, even if the DoJ was inclined to prosecute FARA cases on their own, which it isn’t.

So it’s not likely to have a legal impact (in and of itself, anyway). What about a political impact? That’s going to be tougher to game out, but it hasn’t come up much since Manafort left the campaign, and after today’s announcement it will probably fall off the radar quickly. Manafort stopped working with Party of Regions in 2014, about the time Viktor Yanukovych was heading for the Russian hills after getting chased out of power. That took place long before Manafort became involved in the Trump campaign, so unless the feds find something with which to charge Manafort (still a possibility!), the political impact has already played out.  Manafort didn’t cross the finish line with Trump on the campaign, and at least thus far has not landed a job in the administration. That’s probably the most significant political impact in the long run — Trump won’t be able to bring Manafort into the White House.

That didn’t keep a reporter from asking the easy lay-up question in today’s briefing about what it meant to have an unregistered foreign agent running the presidential campaign. Here’s deputy WH spokesperson Sarah Huckabee Sanders artfully parrying the question by reminding him that she doesn’t represent the campaign. It’s a good reminder of the necessity of vetting, and the virtue of discretion.