The DUX Group, a Washington communications firm, registered under the Foreign Agents Registration Act on November 12, 2026 for Milvest, an Istanbul company led by Turkish businessman Turhan Mildon. The contract pays $40,000 a month for 12 months, $480,000 in total, and covers US media inquiries, monitoring and preparation only. Lobbying and contact with US officials are excluded, and the filing reports none.
Updated November 15, 2026
Summary
A new Exhibit A received by the Justice Department's FARA Registration Unit shows how a press-only engagement for a foreign corporation gets papered under US law. The DUX Group, LLC (registration number 7795) will advise Milvest and Mildon on US public image, handle incoming reporter inquiries and prepare briefing materials. The agreement runs 12 months from October 19, 2026, was signed October 31, and includes a $120,000 nonrefundable payment due on signing. The filing was first highlighted by journalist Eitan Fischberger, who reported that Mildon is the husband of Alina Habba, the former acting US attorney for New Jersey.
Table of contents
- What does the DUX Group FARA filing show?
- What will DUX actually do for Milvest?
- How much is the retainer, and how are the fees structured?
- What is outside the scope of the engagement?
- Why did a PR-only contract still require FARA registration?
- What does this mean for PR firms taking foreign clients?
- Frequently asked questions
What does the DUX Group FARA filing show?
The DUX Group, LLC, based at 707 G Street SE in Washington, DC, filed an Exhibit A for a new foreign principal. The filing, received on November 12, 2026, names Milvest Akaryakit Finans ve Dis Ticaret A.S. of Istanbul as the principal. It checks the box for a foreign corporation, identifies Turkey as the country represented, and leaves the foreign government and foreign political party boxes unchecked.
The agreement is signed by DUX founder and CEO Amos Snead and by Turhan Mildon, who signs as principal and authorized representative of Milvest. Both signatures are dated October 31, 2026.
| Item | What the filing says |
|---|
| Registrant | The DUX Group, LLC, Washington, DC |
| Registration number | 7795 |
| Foreign principal | Milvest Akaryakit Finans ve Dis Ticaret A.S., Istanbul |
| Principal and signatory | Turhan Mildon |
| Term | Twelve months, beginning October 19, 2026 |
| Fees | $40,000 per month, $480,000 total |
| Initial payment | $120,000 for the first three months, due on signing, nonrefundable |
| Signed | October 31, 2026 |
| Received by FARA unit | November 12, 2026 |
What will DUX actually do for Milvest?
The scope of work describes communications counsel for Milvest and for Mildon personally, who together are defined as "the Client." DUX works at the direction of Mildon and reports only to him. The services center on US public image and fall into four areas:
- Media inquiries: DUX receives, assesses and tracks incoming US press inquiries, recommends whether and how to respond, and drafts responses for the client's review.
- Monitoring: DUX tracks US media coverage and flags matters that merit attention.
- Preparation: DUX prepares holding statements, questions and answers, and briefing materials, and helps prepare the client for any media contact he approves in advance.
- Advice: DUX advises on the public image side of the engagement as it develops.
DUX also agrees not to release anything about the engagement publicly without the client's written approval. In plain terms, this is a defensive, reactive media-relations brief rather than a proactive campaign.
How much is the retainer, and how are the fees structured?
The fee structure follows a familiar agency pattern with a heavy front-load:
- Monthly retainer: $40,000 per month, for $480,000 over the 12-month term.
- Upfront payment: The first three months, $120,000, are due on signing and are nonrefundable.
- Ongoing billing: From month four, DUX invoices at the start of each month, payable within 30 days.
- Expenses: Travel and general expenses are billed at cost with receipts. Any single expense over $5,000 needs the client's written approval first.
- Legal fees: Legal fees DUX incurs in good faith to advance the engagement count as reimbursable expenses and are not subject to the $5,000 approval threshold, though DUX agrees to use commercially reasonable efforts to keep the client informed.
Either side can end the engagement with 30 days' written notice. Fees earned and expenses incurred through the termination date remain due.
What is outside the scope of the engagement?
The "Outside the Scope" section is the most telling part of the contract. It excludes:
- advice on the client's business dealings or any company in which he holds an interest
- efforts on behalf of family members or other third parties
- lobbying, government relations, and contact with US government officials
- proactive media outreach, unless the client approves it in writing in advance
The filing repeats the point in its answers on political activities. DUX says it has received media inquiries about contacts between the client's principal and members of the US government, has responded, and reports no lobbying and no contact with US officials or members of Congress. The political activity table reads "No Political Activity Contacts to Report."
Why did a PR-only contract still require FARA registration?
FARA is a disclosure law. It requires people who act in the United States for or in the interests of a foreign principal to register when they engage in covered activities, including political activities and public relations or publicity work. Registration does not imply wrongdoing. The Justice Department describes the act's purpose as public disclosure, so the government and the public can evaluate those activities.
Two details in the DUX filing stand out:
- Item 10 is marked "Yes." DUX confirmed that its activities include political activities as defined in Section 1(o) of the act, then explained that they consist of responding to press inquiries and involve no lobbying.
- Item 11 is marked "Yes." DUX reports registrable activity before the registration date, which matches a term that began October 19 and a contract signed October 31. The filing also includes an October 24 email from Snead to a New York Times reporter conveying a spokesperson statement on Mildon's behalf. In that statement, the client disputes several points in the reporter's questions and says he will pursue legal options if information he considers false is not removed.
The contract also reserves DUX's right to seek an advisory opinion from the Justice Department's FARA Unit if its counsel advises it. That is a quiet signal of how carefully the firm is treating the question of where media advice ends and registrable activity begins.
What does this mean for PR firms taking foreign clients?
For the communications industry, the filing is a clean case study in how a press-only engagement gets documented under FARA. Five lessons stand out:
- Define the scope in writing and name what is excluded, especially lobbying and government contact.
- Say who the client is. Here "the Client" covers both the company and its principal.
- Control the channels. The contract names one point of contact on each side with authority to bind their entity.
- Plan for legal costs up front, since reporter inquiries can escalate quickly.
- Register early and disclose activity that predates the filing.
FARA filings are public, and reporters now read them closely. Every statement made on a client's behalf can become part of the record, which is why scope language, approval rights and documentation matter as much as the media strategy itself.
