The president’s pardon for his son stretched back to Jan. 1, 2014, and covered all other charges Hunter Biden could face, including violations of the Foreign Agents Registration Act.

Hunter Biden had come under investigation by the Department of Justice and House Republicans for possible breaches of FARA that were related, in part, to his lucrative seat on the board of the Ukrainian energy company Burisma, a position he was given in 2014 while his father was vice president.

Under FARA, U.S. citizens who work as “agents of a foreign principal” are required to disclose to the U.S. government any lobbying and public relations work they are doing on behalf of foreign entities. A FARA conviction carries a maximum penalty of up to five years in prison.

Last year, House Republicans and the conservative group America First Legal brought to light emails between Hunter Biden (in his capacity as a Burisma board member), Obama administration officials, and a U.S. firm called Blue Star Strategies that suggested the first son was, in fact, engaging in lobbying during his time on Burisma’s board.

One indication that the president may have skirted FARA is the revelation last year that Blue Star Strategies, which the first son sought out to help Burisma in 2015, was forced to retroactively register its Burisma lobbying work under FARA in 2022 after coming under DOJ investigation.

“Notably, the pardon covers the entire time that Hunter served on the board of Burisma, the Ukrainian natural gas company, and improperly lobbied the U.S. government on its behalf,” Reed Rubinstein, America First Legal senior vice president, said in a statement.

Special counsel David Weiss brought two indictments against Hunter Biden last year but never charged him under FARA. In the first case, Hunter Biden was convicted by a jury of illegally possessing a gun while addicted to drugs. In the second case, he pleaded guilty to nine tax charges.

Critics of the Biden family were far more interested in the tax case, which shed light on Hunter Biden’s income from his business dealings abroad. He made more than $7 million from his foreign ventures in a four-year period while failing to pay his income taxes, the indictment revealed.

The House Oversight Committee, which led Republicans’ wide-ranging impeachment inquiry into the president, had shown in its own sprawling investigation of the Biden family that both Hunter Biden and his uncle James Biden raked in millions of dollars by invoking the president’s name to their foreign partners in Ukraine, China, and elsewhere while offering scant services in return for the money. The Republicans alleged that the president helped his son and brother to profit by improperly flaunting his political influence in phone calls and meetings, an allegation all three Bidens have denied.

A senior aide with the committee told the Washington Examiner that Hunter Biden, in particular, was only ever charged with a “fraction of the crimes he committed.”

“Due to President Biden’s broad and sweeping pardon, Hunter Biden will escape accountability for numerous offenses,” the aide said. “This exemplifies corruption at its core.”

The aide also credited two IRS whistleblowers, both of whom worked as criminal investigators on the DOJ’s investigation into Hunter Biden, with exposing “politicization and misconduct” at the department. Weiss willfully allowed the first son to avoid additional charges and prevented a deeper examination of the Biden family’s foreign income, the whistleblowers alleged. Weiss has denied extending Hunter Biden any special treatment.

The whistleblowers were the first to reveal last year that a FARA charge against Hunter Biden had been on the table but that prosecutors appeared uninterested in exploring the option and eventually allowed its five-year statute of limitations to expire.

One of the whistleblowers’ lawyers, Tristan Leavitt, who is president of the whistleblower advocacy group Empower Oversight, told the Washington Examiner that attaching conspiracy charges to the FARA charge could reset the statute of limitations and reopen a case against the Bidens.

A Trump DOJ and FBI could have pursued such a prosecution, but now they cannot because of the pardon. Trump’s nominee for FBI director, Kash Patel, has explicitly said Hunter Biden should have been prosecuted for FARA and possibly bribery had it not been for what Patel perceived was a “two-tier system of justice.”

Trump’s intention to dramatically shake up his DOJ by putting figures such as Patel in charge could explain the breadth of the president’s pardon, which was historically sweeping and prompted comparisons to the pardon former President Richard Nixon received in the Watergate era. The pardon covered all crimes Hunter Biden has or may have committed during an 11-year period.

“This appears to be the broadest presidential pardon in American history, covering any potential criminal act Hunter Biden ever committed back to 2014, when the Bidens’ dealings in Ukraine netted Hunter a $1 million/year contract with Burisma,” Leavitt said, adding that the pardon “raises major questions the American people need answered.”

White House press secretary Karine Jean-Pierre said Monday that the president plans to issue more pardons before he leaves office, but it remains unclear whether he will extend a pardon to his brother James Biden to erase any exposure he might have to FARA or other charges in a Trump administration.