Rudy Giuliani, the former New York City mayor turned personal attorney to former President Donald Trump, continues to face significant legal exposure to an ongoing criminal investigation by the Manhattan U.S. Attorney’s Office, after he was not among the dozens who received a pardon in the waning hours of the Trump administration, lawyers said this week.

Giuliani, who has reportedly been under investigation for more than a year by the office he once led in the 1980s, became the face of Trump’s efforts to overturn the results of the 2020 election, pushing a series of legal challenges that failed to produce his long-promised evidence of widespread fraud.